Human Resources (HR) Privacy Policy

As part of any recruitment process, Gem Hotels collect and process personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

What information do we collect?

Gem Hotels collect a range of information about you. This includes:

  • Your name, address and contact details, including email address and telephone number;
  • Details of your qualifications, skills, experience and employment history;
  • Information about your current level of remuneration, including benefit entitlements;
  • Whether or not you have a disability for which us needs to make reasonable adjustments during the recruitment process; and Information about your entitlement to work in the UK.

Gem Hotels may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

We may also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why do Gem Hotels process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, it is mandatory to check a successful applicant's eligibility to work in the UK before employment starts.

Gem Hotels has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

Gem Hotels may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out our obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, Gem Hotels may keep your personal data on file in case there are future employment opportunities for which you may be suited. We may ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks, and pension/insurance providers, HMRC, HM Government, lawyers, accountants, auditors or any other legitimate businesses requiring your data. 

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business or in connection with a TUPE transfer. We may also need to share your personal information with a regulator or to otherwise comply with the law.

How do Gem Hotels protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long do Gem Hotels keep data?

  1. Successful Job Applicants

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. After employment, your data may be kept up to 6 years on our systems.

  1. Unsuccessful Job Applicants

If your application for employment is unsuccessful, we will hold your data on file for 6 (six) months after the end of the relevant recruitment process. At the end of that period, or once you have withdrawn your consent, your data will be deleted or destroyed. You may be asked, when you submit your CV or at interviews, whether you give us consent to hold your details for 6 months in order to be considered for other positions or not.

Your rights

As a data subject, you have a number of rights.

You can access and obtain a copy of your data on request;

  • require us to change incorrect or incomplete data;
  • require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data where Gem Hotels is relying on its legitimate interests as the legal ground for processing.

You can exercise those rights at any time. To get further information regarding the processing of your application data, please visit our general Privacy Policy web page.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Gem Hotels 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.


If you would like to get in touch with us, please contact

  • By Email:
  • By Post: DPO, Globalgem Hotels Limited, 72-75 Red Lion Street, London, WC1R 4GB

Last updated

This policy was last updated on 4th Jul 2020