March 2024
Application: Global Privacy Notice for Candidates/Prospects
Confidential
Sky is committed to protecting the privacy and security of your personal information.
This Privacy and Cookies Notice applies to the processing of personal data that you provide during your Recruitment Process with Sky (this includes use of our preparation hub, registration of interest for future roles, application for specific roles, assessment, selection, hire and on-boarding). In this privacy notice, we will explain to you:
1. Who we are
Depending on the company you’re submitting your application or registration of interest to, your personal data may be processed by the following controllers:
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United Kingdom and Republic of Ireland (including branches in Belgium, Portugal, Denmark Poland, and Czechia) - Sky UK Limited, Sky Ireland Limited, The Cloud Networks Limited, Sky Studios Limited, Sky Subscribers Services Limited, Sky In Home Service Limited, Sky (CP) Limited, Sky Retail Stores Limited
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Italy - Sky Italia S.r.l., Sky Italia Network Service S.r.l., Vision Distribution S.p.A., Digital Exchange S.r.l.
In this Notice, we will use the terms “Sky”, “we”, “us” and “our” to refer to the company to which you have submitted an application or registration of interest, and other companies in the Sky group of companies.
2. Types of information we process and where it comes from
We will collect data directly from you when you communicate with us during the Recruitment Process (including your name, email address, phone number, CV and any other information you choose to include). We may also collect data about you indirectly, where you have made it publicly available on external sources such as LinkedIn and Job Boards, but we will only continue to process this data if you agree.
The types of data we process will vary according to the country in which you are applying for a role and the stage of the recruitment process you reach.
The kind of information we may hold includes, where applicable:
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Information required to register your interest for future opportunities or to register to use our Early Careers Preparation Hub, including your name, contact details, and any other information you choose to provide.
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Credentials (email address and password) required for you to create an online account to apply for roles and manage your application.
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Information required for you to submit an application for a role, including:
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United Kingdom and Republic of Ireland: Your name and contact details and, if you choose to provide it, your preferred name, marital status, disability information, ethnicity, gender identity, age-range, religion, sexual orientation and social mobility information such as type of school attended. If your application is submitted on your behalf by an agency, further information may be collected where you have chosen to provide it, including citizenship status, date, country and city of birth, legal gender and primary nationality.
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Portugal: Your name and contact details and, if you choose to provide it, your citizenship status, city of birth, gender identity and additional nationalities.
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Czechia: Your name and contact details and, if you choose to provide it, your preferred name.
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Italy: Your name and contact details, information on protected category under Law n. 68/99 where applicable and, if you choose to provide it, your country of birth and citizenship status.
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Information required to offer you a role where your application is successful, including:
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United Kingdom and Republic of Ireland: Your national and/or government ID(s), date of birth, primary nationality and gender and, if you choose to provide it, your citizenship status and city and country of birth.
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Portugal: Your national and/or government ID(s), date and country of birth, primary nationality and marital status and, if you choose to provide it, your gender and disability information.
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Czechia: Your citizenship status.
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Italy: Your national and/or government ID(s), city and date of birth, primary nationality and gender and, if you choose to provide it, your marital status.
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Information required to complete the hire and on-boarding processes where you have accepted an offer, including your username and password to sign into Workday and:
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United Kingdom and Republic of Ireland: Your passports, visas, bank details and emergency contact and, if you choose to provide it, your pronoun, photo, licences and details of any military service.
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Portugal: Your passports, visas, bank details and emergency contact and, where you choose to provide it, your photo and licences.
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Czechia: Your passport, date of birth, gender, marital status, your visas and work permit information if you are a foreign national, your bank details, emergency contact and, if you choose to provide it, your photo.
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Italy: Your passports, visas, bank details, date of birth, gender, emergency contact and photo and, where you choose to provide it, your licences.
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3. How we use your information
Your personal data is used by Sky during the Recruitment Process for the following purposes and legal bases:
For the performance of your contract with Sky or the fulfilment of pre-contractual commitments, including:
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Reviewing your skills, experience and interests and assessing your suitability for specific roles you apply for and where you have registered your interest for roles.
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Contacting you about the Recruitment Process.
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If shortlisted for a role, sharing your data with the hiring managers to allow them to carry out the Recruitment Process. We will only pass on data necessary for the hiring manager to make a decision about whether to select you for the position. This data will not include any sensitive data (such as health or criminal record history).
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Selecting candidates for roles based on personal data and considering specific attributes such as previous experience, if relevant. Part of this selection may be automated. Our recruitment team carries out regular reviews of decisions made in this way to ensure there is no bias, and you may ask us to review any such decisions by using the contact details below.
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For United Kingdom and Republic of Ireland roles only:
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Depending on the role you have applied for, our HR Services team may ask you to complete pre-employment vetting with Disclosure Scotland, Disclosure & Barring Service and Experian, including credit reference and criminal record checks, address verification, confirmation of academic qualifications, and requesting employer or other references from people or companies that you have provided in your application. If the vetting is successful, we will share your data with our colleagues in HR to enable an offer of employment to be made and for on-boarding purposes.
Where Sky has a legal or regulatory obligation, including:
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For the fulfilment of specific obligations laid down by law, company regulations, collective agreements, national and EU regulations and arising from provisions ruled by authorities.
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Responding to legitimate, lawful requests for information from law enforcement and other government agencies and as part of court orders where Sky is legally required to provide the information.
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For reporting purposes when required to do so by law. This may include voluntary equality information, and your data will be aggregated and anonymised for these purposes wherever possible.
Where you have provided your consent, including:
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Collecting information to produce meaningful equal opportunity, diversity and inclusion monitoring and reporting, and to view our progress to becoming a diverse and inclusive workforce. It is your choice whether you provide Sky with your diversity and inclusion data. By choosing to provide us with this data, you consent to this processing. If your application is successful, your diversity and inclusion data will be transferred to your permanent HR record.
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Retaining your data in a Talent Community in order to review your skills, experience and interests and to assess your suitability for roles you may not have specifically applied for but for which you may be suitable.
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To contact you about Early Careers programmes and events.
In reliance on Sky’s legitimate interests, including:
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For the protection of the legitimate rights and interests of Sky and/or third parties, including to support legal and compliance activity including the defence of litigation claims.
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To manage, monitor, assess and improve our recruitment process. Wherever possible, your data will be aggregated and anonymised for these purposes.
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To process the data you have made available on public sites such as LinkedIn, Social channels and Job Boards in order to contact you about joining our Talent Community.
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To contact you for the purposes of market research, including to ask you to complete surveys about your recruitment experience (UK and Ireland group of companies only).
4. How we share your information
We care deeply about your privacy and do everything we can to protect your data. For this reason, we share your data only when strictly necessary and only with those who help us to offer you a better service. The information you provide during the Recruitment Process may be shared with Sky’s Recruitment and HR teams, and:
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Employees, managers and other individuals involved with our recruitment process.
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Other Sky Group companies and companies in the Comcast group, such as where we have joint hiring managers or you are suitable for roles across different companies.
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Suppliers that provide services and activities on behalf or in support of Sky, such as: employment agencies and consultants, management and maintenance of website content, management of information technology systems, payroll data processing services, documentation storage, accountants, personnel accounting management services, immigration advisors and other suppliers that provide global mobility services, health service providers, insurance companies, IT companies, job security companies, brokerage agencies, training companies, freelancers. Where these suppliers act on our behalf, they must only process your personal data in accordance with our instructions.
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Competent authorities when required to do so by law, regulation or court order.
Your information may be held:
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by Sky or by our recruitment partners, such as Randstad Sourceright Limited, Cappfinity Limited, Outmatch, Manpower, Adecco, GI Group, GTI Group, GTI Recruiting Solutions and Allegis Group, and
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on systems operated by Sky or on behalf of Sky, such as Workday Inc., Talent UX, Talent Radar, Sova and Codility.
We may transfer the personal information we collect about you to countries outside of the UK and European Economic Area (EEA). Where the country has not been deemed by the UK and/or the EU to provide an adequate level of protection for your personal information, we will only transfer the data in a way that is consistent with and which respects the UK and EU laws on data protection. Most commonly this will be through Standard Contractual Clauses included in the contract Sky has in place with the third-party supplier.
5. How long we may keep your information
We will only keep your information for as long as we need it for the purpose it was collected. We apply the following retention periods to your information collected during the Recruitment Process.
United Kingdom and Republic of Ireland:
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We will keep your data for 18 months from the date it was collected.
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We will keep your data in our Talent Community for a maximum of 18 months or until you revoke your consent.
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We will keep your data in our Preparation Hub for 12 months from the date it was collected.
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We will keep your interview notes for 6 months from the date of the interview.
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If you are successful in obtaining a role at Sky, we will keep your data for 7 years from the end of your employment.
Italy:
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We will keep your data for 12 months from the date it was collected.
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We will keep your data in our Talent Community for a maximum of 1 year or until you revoke your consent.
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We will keep your interview notes for 6 months from the date of the interview.
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If you are successful in obtaining a role at Sky, we will keep your data for 10 years from the end of employment, or in the case of internship for 12 months from the end of the internship.
6. Your data subject rights
You have the following rights in relation to your personal data:
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To request access to, erasure of, and/or correction of the personal data we hold about you.
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To request us to restrict the processing of the personal data we hold about you.
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To object to us processing personal data relating to you.
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Where you have given us consent to process your personal data, to withdraw that consent at any time.
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To obtain certain personal data from us in a format that can be transferred electronically to a third party (also called “data portability”).
Please note that some of these rights are not absolute, and whether you can exercise your right depends on the circumstances. We will keep you informed throughout the process.
You may update, correct, or modify the information you have submitted during the Recruitment Process, or withdraw your consent where your data is processed on the basis of consent, at any time either by logging back into the online portal or by contacting us using the details below.
All data held by Sky is processed in accordance with all applicable data protection laws, meaning that the data will only be processed and retained for the purposes for which it was originally collected.
You can contact us using the details below if you wish to find out more about how to exercise your subject rights.
7. How to contact Sky
If you have any queries or comments about this Privacy and Cookies Notice, please contact your local HR Team or Data Protection Office:
For the United Kingdom and Republic of Ireland group of companies:
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HR: PeopleServices@sky.uk
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Data Protection Office: By email on dp.department@sky.uk or mail to Data Protection Department, Sky UK Limited, Grant Way, Isleworth TW7 5QD.
For Italy:
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Data Protection Office: By email on dpo@sky.it or mail to Sky Italia s.r.l. – Direzione Affari Legali – Data Protection Officer, Via Monte Penice 7, 20138 Milan.
8. How to raise a complaint
If you wish to make a complaint about how Sky uses your information, please contact your local Data Protection Office on the above email addresses and we will do our best to help. If you are still unhappy, you can contact your Data Protection Authority as follows:
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For the UK group of companies listed above, the Information Commissioner’s Office: https://ico.org.uk/make-a-complaint/
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For Republic of Ireland, the Data Protection Commissioner: https://forms.dataprotection.ie/contact
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For Italy: Garante per la protezione dei dati personali: www.garanteprivacy.it
9. Cookies Notice
Cookies are created when you visit a website or use an app. They are small files that are stored on your device and they are necessary for the functioning of the website or app.
What do we use cookies for?
Sky’s recruitment site uses technical essential cookies only. Technical essential cookies are necessary to make sure our site is working properly, and are needed to provide the content, product or service you have asked for. The cookies used on our site are:
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Session management cookies - User, device and session ID cookies along with timestamp cookies for timing out sessions after inactivity. These cookies expire at the end of the session.
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such as “PLAY_LANG”, “PLAY_SESSION” and “timezoneOffset” used to provide the user with a consistent session.
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Routing cookies - To forward requests for a single session to the same server for consistency of service. These cookies expire at the end of the session.
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Load-balancer cookies such as “wday_vps_cookie” and “WorkdayLB_VPS” which are used to ensure a single session is handled by the same server so that the user isn’t inadvertently logged out.
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Application Security Management (ASM) cookies - To help protect web applications and infrastructure from security attacks. These cookies expire at the end of the session.
Managing your cookie preferences
We don’t give you the option to turn off technical essential cookies when you visit Sky’s recruitment site because these cookies are necessary to make the site function properly.
Most modern browsers allow you to see what cookies you have on your device and to clear them all or individually. To find out how to do this, go to aboutcookies.org, which contains comprehensive information on how to do this on a variety of browsers. Please remember that any settings you change will not just affect the cookies we use. The changes will apply to all websites you visit unless you choose to block cookies only from specific sites.
Changes to this notice
We will occasionally update this Privacy and Cookies Notice. These updates will be communicated through dedicated channels. We encourage you to periodically review this Notice to be informed of how we use your information.
This Privacy and Cookies Notice was last updated on 01.03.2024.