Privacy Notice

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Who are we?

A key driver to delivering A Better Tomorrow™ is values which guide our culture and behaviours across the entire Group, ensuring an organisation that is future-fit for sustainable growth. These six values are ‘Truly inclusive’, ‘Do the right thing’, ‘Love our consumer’, ‘Passion to win’, ‘Empowered through trust’ and ‘Stronger together’. They are embedded across the Group and underpin how we will drive progress to deliver sustainable growth.

At BAT how we deliver our business results is fundamental to achieving our purpose of A Better Tomorrow™: acting ethically and in line with our values will deliver a long-term sustainable business that meets the expectations of our consumers, employees, investors, and society as a whole.

At BAT we are committed to protecting the privacy of our candidates, and also users of this eRecruitment Site ("Site"). We will ensure that the information you give to us (for example via this Site) is only used for the purposes set out in this Privacy Notice. We are committed to acting responsibly and with integrity with regard to protecting your privacy rights and freedoms.

For the purpose of this Privacy Notice and applicable data protection legislation (including but not limited to the UK General Data Protection Regulation (“UK GDPR”) and EU General Data Protection Regulation (“EU GDPR”), the primary company responsible for your personal data is British-American Tobacco (Holdings) Limited whose address is Globe House, 4 Temple Place, London WC2R 2PG (“BAT Holdings”).

BAT Holdings is responsible for any personal information that you:

• Provide in this Site (e.g., registration details, name, email address, background details); orr
• Provide to one of our recruitment agents based in the UK in the context of a permanent or temporary role (e.g., email address, CV, cell number); or
• Provide to a third party recruitment agency who passes our UK based recruitment colleagues your details for consideration (e.g., email address, CV).

We also may share or transfer your details with or to other companies in the BAT Group. This is because you may be applying for a job (permanent or temporary) in another BAT Group company and BAT Holdings has the role of being initially receiving, and being responsible for, your personal data until such point it is passed to another BAT Group company.

At this point, it is the second BAT Group company receiving your personal data which will then be solely responsible for any other of your personal data you provide to them subsequently in connection with any job application. They may serve you with another Privacy Notice similar to this one if required to do so by law.

Companies which are responsible for your data in this context are known as ‘data controllers’ and you may see reference to this within this Privacy Notice.

However, if you apply for a job (permanent or temporary) with another BAT Group Company which is listed below this Privacy Notice shall apply to all processing of your personal information within the recruitment application process (for ease, we have abbreviated to refer to these companies as “Centre Entities” or a “Centre Entity”)). Remember, if you are unsure which Centre Entity applies to you then please contact us.

Centre Entities

This Privacy Notice gives you details on how we collect, use and process your personal information, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your rights.

Contents

1. What information do we collect about you and how we use your information?
2. Where does the information we use about you come from?
3. Who do we share your information with?
4. How long do we keep your information?
5. How do we ensure your information is safe with us?
6. What are your rights under data protection law?
7. Automated Decision Making
8. How can you contact us?
9. Changes to this Privacy Notice

1. What information do we collect about you and how we use your information?

Please see information below which sets out what personal information we hold about you, the reason why we use it and the law lets us do this.

2. Where does the information we use about you come from?

Your information that we collect is based on information that you share with us which include:

• when you register with on this Site (for example when you sign up to be a registered user);
• where you contact us proactively, usually by phone, email or via social media; and/or where we contact you, either by phone or email you may provide us with information during such communication.

We also collect other information from other sources.

• If you choose to apply or submit information using Facebook or similar social media sites, we import the requested information from your social media account and we make it part of your profile. For details on how your personal data is handled and processed by the social media Site that you have used to submit your information, please consult the Privacy Notice on that social media site.
• We also collect your personal information when you visit the Site such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We use the information for statistical reporting and do not link it to any named individuals.
• We also receive and use your personal information when you provide it to a recruitment agent working in the UK (either for a Centre Entity role or another role with a BAT Company but the recruitment colleague at BAT is in the UK), or if you have applied for a role through a third party agency which will pass us your details;
• If you are applying for a role with a Centre Entity, after you have made the application, we may seek more information about you from other sources generally including from third parties. For example, we may receive information on you from those organizations that you have asked us to use for professional or academic references such as a previous employer or a college or university.

BAT will not intentionally collect any information about registered users to this Site who are under eighteen years of age. If BAT becomes aware that a child has provided any information this will immediately be deleted from BAT's records.

3. Who do we share your information with?

We will share your personal information primarily to ensure we provide you with the most relevant and up to date news, content and events, or to ensure we can respond to any query quickly and expeditiously. Unless you specify otherwise, we may share your information with any of the following groups:

• Any of our Group BAT companies. As identified in this Privacy Notice, your personal information will be shared with the BAT company responsible for the job that you are applying for. You may apply for several different jobs. Depending on the location of the job that you choose to apply for your personal information could be transferred inside and outside the UK for such purposes as enable them to continue any local recruitment services to you worldwide. You may like to know that the place of central processing administration of personal information in the context of recruitment activities is in the EU and via a BAT company called British American GBS Recruitment SRL in Romania. This BAT company undertakes the majority of recruitment processing on our behalf. To contact this entity’s Data Protection Officer, please use the contact details provided at the end of this Privacy Notice.
• Tax, audit, or other authorities, when we believe that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation) or in order to help prevent fraud or to enforce or protect the rights and properties of BAT or its subsidiaries; or protect the personal safety of BAT employees, third party agents or members of the public;
• Third party service providers who perform functions on our behalf (including local recruitment agents, email communications service providers and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems), third party outsourced IT providers where we have an appropriate data processing agreement (or similar protections) in place;
• If a BAT entity merges with or is acquired by another business or company in the future, we may share your personal data with the new owners of the business or company (and provide you with notice of this disclosure);
• Circumstances may arise where, whether for strategic or other business reasons, BAT decides to sell, buy, merge or otherwise reorganise businesses in some countries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it from sellers. It is BAT’s practice to seek appropriate protection for personal information in these types of transactions.

We do not share, rent or trade your information with third parties for marketing or promotional purposes.

Please note that we may ask you to take application tests by using testing tools of third parties for which you will have to register as user. The third party provider may allow you to use your test results for applications with entities other than BAT, so that your data is stored to your account with the provider beyond the duration of your application process with BAT. You will be provided for separate and detailed information by the third party provider before logging on to its respective service.

4. How long do we keep your information?

We will not keep your personal data for any longer than is necessary for the purposes for which we collect it. If you are not successful for a job application, we may retain your details and CV so that your information is available already in your profile for potential future roles matching your experience. However, you can delete your profile and registration at any time – it is within your control. Otherwise, it will be deleted after 18 months of your last logging into the profile.

In addition, we may be required by law to retain your data e.g. in respect of equal opportunity claims, or to defend or bring legal claims. Where we are subject to a regulatory or other legal obligation in a specific jurisdiction which requires us to keep data for a specified period, we will comply with those regulatory requirements with respect to the retention of such data e.g. Visa record keeping requirements in the United Kingdom.

5. How do we ensure your information is safe with us?

We care about protecting your information. That is why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.

We are committed to taking appropriate steps to protect your information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

Unfortunately, there is always risk involved in sending information through any channel over the internet. The information you send over the internet entirely at your own risk. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted over the internet.

If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately. Please raise your concern by contacting us (using the details below) or by using the Contact us section of this website, in the first instance, and we will investigate the matter and update you as soon as possible on next steps.

If you receive any emails from us that you suspect are not from BAT please report them here: phishing@bat.com

6. What are your rights under data protection law?

You have rights under data protection law in relation to our use of your information, including to:

• request access to your information, which you can do by emailing us at recruitment_dataprivacy@bat.com
• update or amend your information if it is inaccurate or incomplete;
• object to certain uses of your information in situations where we rely on our legitimate interests to do process your information;
• request the deletion of your information, or restrict its use, in certain circumstances (for example you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected (unless certain exceptions apply);
• where you have given your consent to process your personal information you are entitled to withdraw this
• ask for the return of information you have provided to us, to use for your own purposes (often called your right to data portability) where the processing is based on your consent or for the performance of a contract; and the processing is carried out by automated means;
• lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk/global/contact-us/email/) for individuals in the United Kingdom. For all other EEA supervisory authorities please see the list of the privacy regulators for each Member State (along with contact details) on the following website: https://edpb.europa.eu/about-edpb/board/members_en

7. Automated Decision Making

We may make automated decisions when selecting who to include on a shortlist for interview via CV screening methodology, via a general criteria assessment questionnaire or through our partner’s talent assessment technology platform.

The talent assessment technology helps BAT to learn more about you, above and beyond what’s on your resume and application form. It provides unbiased, multi-dimensional insight into your potential for success at BAT. The methodology involves a series of games, or exercises. Nevertheless, in line with UK GDPR and GDPR, you are guaranteed with a human intervention and possibility to express your point of view and to contest the decision if desired. Should you be requested to go through the Pymetrics games as part of our recruitment process, please be advised that you are free to refuse to be subject to automated decision making and you can request a recruiter to check your application at recruitment_dataprivacy@bat.com.

If you would like to know more about this (such as information on the logic involved in the decision and the envisaged consequences for you), please contact us (see section 8 below).

8. How to Contact Us

If you have any comments or suggestions concerning this Privacy Notice, please contact us using the contact details stated in the job specification relating to the vacancy for which you have applied or at recruitment_dataprivacy@bat.com or data_privacy@bat.com.

9. Changes to this Privacy Notice

We keep this Privacy Notice under regular review, please check back at this page in the Site for updates. This Privacy Notice was last updated on 6th December 2023.