Privacy Statement
Before you submit your application, please read this statement regarding the use of your personal information. Please do not submit any information if you do not want it to be dealt with in the ways described in this following notice.
If you are applying for a job or employed by us in the United Kingdom we are Smiggle UK Ltd (company number 06720710) whose registered office is at 10 John Street, London, WC1N 2EB and if you are applying for a job or employed by us in Ireland we are Smiggle Ireland Limited (company number 591250) whose registered office is Block A, 5th Floor The Atrium, Blackthorn Road, Sandyford, Dublin 18 (‘Smiggle, we, us, our’). We collect and processes personal information relating to job applicants and employees. We are a registered data controller at the UK Information Commissioner’s Office under number ZA025548. We are also part of Just Group Limited ACN 096 911 410 whose registered office is at 457 St Kilda Road, Melbourne, Victoria, 3004, Australia (‘Just Group’).
Why we hold your personal information
We hold your personal information based on our legitimate interests and contractual obligations. Without such personal information we would be unable to employ you. We have a legitimate interest in processing personal information during the recruitment process for keeping records of the process. Processing personal information from job applicants lets us manage the recruitment process, determine an applicant’s suitability for employment and decide who to employ. We may also need to process personal information from applicants to respond to and defend legal claims. It also enables us to meet various administrative and legal obligations, for example, it is mandatory to check a successful applicant’s eligibility to work in the UK before employment starts and in some cases throughout employment.
If you are successful in your application or a current employee then we continue to process your personal information based on our contractual and statutory obligations (without this we wouldn’t be able to employ and /or pay you). We may also process your personal information in other circumstances, provided you have given your consent for us to do so. If in the future we intend to process your personal information for a purpose other than that for which it was collected, we will always let you know, provide you with the relevant information and if appropriate seek your consent.
You are under no statutory or contractual obligation to provide personal information to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
What information do we collect
  • Identity information including personal contact details such as full name, title, date of birth, photographs and images;
  • Contact information including addresses, telephone numbers and personal email addresses;
  • Financial information including bank account details, tax file numbers and national insurance numbers;
  • Employment information including your CV, references, details of your education, qualifications and previous work experience;
  • Nationality, immigration and Residency information including visa requirements, copies of passports and visas;
  • Other information including information about your remuneration and benefits, hours and days of work, emergency contact details, professional memberships, contract of employment and amendments, letters, emails, appraisals, performance review, equal opportunities monitoring information, disciplinary or grievance records and records of holiday and sick leave;
  • CCTV and your image. In some of our higher risk stores, we use CCTV to prevent and detect crime. If your application is successful and you are employed in these stores, your image may be captured; and
  • Sensitive categories of information including whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process, information about your racial or ethnic origin, age, gender, religious or philosophical beliefs and physical or mental health information. We process this information to carry out our obligations and exercise specific rights in relation to employment including equal opportunities monitoring.
How do we collect this information
We can collect information about you in a variety of ways including as provided directly by you such as in application forms, CVs, obtained from your passport or identity documents or collected through interviews. We may also collect personal information about you from third parties including from employment agencies, managers, referees and from publicly available sources such as LinkedIn. We will also collect additional personal information in the course of job-related activities whilst you are working for us. Your personal information may be stored in different places, including on your application record, in our HR management system, payroll system, and in other IT systems such as by email. We also monitor computer, telephone/mobile telephone use and email, as detailed in our policies which are available on Just Us or through our People & Culture Department. This is necessary to protect our legitimate interests in relation to fair usage and acceptable standards of communications internally and externally.
Your personal information is stored securely with us whether in electronic or physical form. We take all reasonable steps to protect all personal information from misuse, loss, interference, unauthorised access, modification or disclosure including by:
  • Providing information on a need to know basis only;
  • Enforcing a policy of not sharing passwords and log in information;
  • Ensuring that personal information is kept on secure drives with limited access;
  • Limiting as much as possible the use of paper-based personal information; and
  • Ensuring safe-keeping and safe disposal of physical documents.
Data Transfers
We may need to send some of your personal information to the Just Group in Australia. We also use some third parties in our business to deliver services, so some of the uses and disclosures may occur outside of your country of residence. This means that sometimes we’ll need to transfer your personal information between countries and in particular to Australia (where our head office is). If you’re in Europe, this means we may transfer your personal data to other jurisdictions for processing in a destination outside the European Economic Area (‘EEA’) which may not provide the same level of protection of personal data as within the EEA. By submitting your personal data, you agree to this transfer, storage and processing. While we transfer personal data outside of the EEA, we will take reasonable steps to protect your information and prevent any third parties outside of your country of residence using your personal information in any way that is not set out in our privacy policy. If we do transfer your personal information out of the EEA, our standard practice is to use standard data protection clauses for such transfers. You can request a copy by contacting our data protection officer on the details below. And, if you’re resident in Ireland, you agree and acknowledge that we may disclose your personal information to any member of our group as defined in section 155 of Companies Act, 1963 (as amended), which includes our subsidiaries, our ultimate holding company and its subsidiaries.
Sharing your information
Your information may be shared internally for the purposes of the recruitment exercise and if your application is successful or you are a current employee, for the purposes of your employment with us. This includes with members of the People & Culture team, interviewers involved in the recruitment process, external recruiters, managers, finance, legal and IT staff. We will only disclose information about you to third parties where we are legally obliged to do so or where we need to do so to comply with our contractual obligations to you or if you have provided your consent. For example, we may need to pass on certain information to an external benefits provider, pension or insurance schemes or when you have given express authorisation for us to do so. We also engage trusted third party providers who we may disclose your information to such as software providers, contractors and external organisations engaged to conduct recruitment assessments. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We will never provide personal information gathered in our employment relationship to a third party for commercial purposes. Further, in some circumstances we may be legally obliged to disclose your personal information, for example to law enforcement agencies when required by law.
How long will we keep your information
If your application is unsuccessful then we will hold your information for a further six months and we may contact you if a suitable opportunity arises in the future. Please withdraw your application through your account on our website or contact us if you do not wish for us to contact you in the future about suitable opportunities. If your application is successful or if you are a current employee, the personal information collected during the recruitment process is transferred to your employment file with us and will be retained with further information collected during your employment in accordance with our legal obligations for retaining such information (usually six years after your employment has been terminated for legal, accounting and reporting requirements).
Your rights
You have a number of rights. You can:
  • Access and obtain a copy of your information on request;
  • Require us to change incorrect or incomplete information;
  • Require us to delete or stop processing your information, for example where the information is no longer necessary for the purposes of the processing;
  • Withdraw your consent where you have provided your consent to the collection, processing and transfer of information for a specific purpose;
  • Object to the processing of your information where we are relying on our legitimate interests as the legal ground for processing;
  • Request that we transfer your information to someone else (in certain circumstances); and
  • Complain to the Information Commissioner if you believe that we have not complied with your data protection rights.
If you would like to exercise any of these rights or have any questions in relation to this privacy notice, please contact our Data Protection Officer by email at