Recruitment Data Protection Policy

Millar, Inc. ("Millar") Recruitment Application Form Data Protection Notice

In applying to join the Millar team as an employee, you will be providing us with certain information about yourself that can be used to identify you as an individual (Personal Data).  This notice sets out how we will process this Personal Data and comply with the various laws to which Millar is subject, including the General Data Protection Regulation 2016/679, to ensure that we deal with your Personal Data in an appropriate manner.

Who are we?

Your Personal Data will be processed by Millar, and Millar will be the data controller of that Personal Data.  We may pass all or part of your data between other relevant Millar group companies to the extent permitted under local law for the purpose of your recruitment selection and if you are taken on, as part of your employment. 

What Personal Data may we collect about you and why?

As part of your recruitment process we may collect, where permitted by local law and as appropriate:

  • Your contact details, CV or résumé, application form details (to the extent permitted under local law), interview notes, national insurance or other identification number, and your visa, passport or permission to work documentation, references from former employer(s); [and]
  • Details of your ethnic background and disabilities you may have and whether you have been long term unemployed strictly for the purposes of monitoring compliance with anti-discrimination legislation and our policies.

We may submit such Personal Data to our third party service provider, HR Alliance, and may permit it to process the Personal Data on our behalf for the purposes set out in this Data Protection Notice. HR Alliance is contractually prohibited from using Personal Data for any purpose other than for the purpose specified our contract with it, and will be subject to obligations to process Personal Data in compliance with the same safeguards that we deploy.

Once you have agreed to an offer letter, we may also undertake criminal records checks or other independent searches and where we do so you will be asked to consent to such collection and use before we or our agents undertake the search to assess your suitability for the position.

We do not conduct any vetting of applicants aside from ascertaining an applicant’s legal ability to work.

Where reasonably necessary or required to do so, we may disclose these details to third parties in relation to law enforcement or regulatory investigation and also for the purpose of conducting any pre-employment checks (to the extent that these are permitted under local law).

If you are taken on to work at Millar we will collect other Personal Data, in accordance with our internal Employees and/or Workers data processing notice.

On what basis will we assess your application?

We will assess your application on the basis of your suitability to the advertised role. 

We shortlist applicants using a manual selection process, considering appropriate experience and skills for the job.

What legal basis do we have for using your Personal Data?

We process your Personal Data in order to assess your application prior to entering into an employment contract with us and pursuant to laws to which Millar is subject (e.g. in relation to equal opportunities).  This processing is a necessary pre-condition of entering into any future contract with you and for Millar to fulfil its obligations with respect to other employees and yourself (should you be employed by Millar). If you are unable to provide us with the information requested, we may be unable to assess your appropriateness for the job applied for or to communicate with you.

When do we send your Personal Data abroad?

We hold your Personal Data principally in the country in which you apply for a role. However, it is sometimes necessary for us to provide details about your application to other Millar companies for the purposes of your selection, situated outside the European Economic Area, and we may use service providers and agents in the administration of our business.  When we do so, we will ensure that such transfers ensure that an appropriate level of protection is given to the Personal Data (and we use EU approved “Model Clauses” where appropriate in order to ensure this). Human Resources can provide you with a copy upon request.

How long do we keep your Personal Data for?

We keep records of your data for no longer than is necessary for the purpose for which we obtained them and any other permitted linked purposes.  If your application is unsuccessful, we will retain your information for a minimum of twenty four (24) months. However,  deletion of files may be suspended where required by law or to defend ourselves if we consider a complaint or dispute to be likely.

What are your rights in relation to the Personal Data we collect?

Subject to various exceptions and data protection laws in your country, you may have the following rights:

(a) Access: you can ask us to provide you with further details on the use we make of your Personal Data and a copy of the Personal Data we hold about you;

(b) Correction: you can ask us to correct any inaccuracies in the Personal Data we hold about you;

(c) Complaint: if you are not satisfied with our use of your Personal Data or our response to any exercise of these rights, you have the right to complain to the data protection authority in your country;

(d) Erasure: you can ask us to delete your Personal Data if we no longer have a lawful ground to use;

(e) Withdrawal of consent: where processing is based on consent (e.g. marketing), you can withdraw your consent to processing so that we stop that particular processing 

(f) Object to processing: you have the right to object to other types of processing (e.g. analytics and profiling activities carried out in relation to your Personal Data), unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;

(g) Restriction: you can restrict how we use your Personal Data, for example whilst we are verifying the accuracy of your Personal Data or where we are verifying the grounds that use as the basis of holding your Personal Data;

(h) Portability: where technically feasible, you have the right to ask us to transmit the Personal Data that you have provided to us to a third party in a structured, commonly used and machine readable form.

Contacting us

If you have any questions about this Data Protection Notice or our processing of your Personal Data, please contact us at :

Human Resources
Millar Inc.
6001-A Gulf Freeway
Houston, Texas 77023
Phone: +1 832.667.7133
Fax: +1 713.714.8497

Last Updated: May 18, 2018