BRG GROUP
JOB CANDIDATE DATA PRIVACY PROTECTION POLICY
Last updated: September 2024

Objective

The following Job Candidate Data Protection Privacy Policy (the “Policy”) applies to each individual who applies for a job at an entity that is part of the BRG Group of Companies (hereinafter, collectively referred to as “BRG Group”) which includes:

Breville Canada, L.P.
Breville Korea Limited
Breville Mexico, S. A. de C.V.
Breville New Zealand Limited
Breville Pty Limited
Breville Services (Shenzhen) Company Limited
BRG Appliances Limited
BRG Middle East Appliances L.L.C.
HWI International Limited
Sage Appliances France
Sage Appliances GmbH

including the brands Baratza, Beanz, Breville Commercial, Sage Commercial, Lelit, ChefSteps, ControlFreak, FoodThinker and others (collectively as “BRG Group”, “we”, “ours”, or “us”).

The purpose of this policy (the “Policy”) is to provide adequate and consistent safeguards for the handling of candidate data by all BRG Group entities.

The Privacy Policies explain how we collect, use or otherwise process personal data when you access or use the BRG Group websites, mobile applications, connected devices, and other products and services (collectively, the “Services”), or when you otherwise interact with us.

The identifiable information about yourself that you provide to a BRG Group entity as a job seeker for a position with a BRG Group entity (the “Candidate Data” or “Data”) will be used for recruitment purposes, and the Candidate Data will be protected in accordance with the Policy outlined below and all applicable laws.

By submitting your Candidate Data, you confirm and agree that:

• you have reviewed the Policy;
• BRG Group may process the Candidate Data according to the recruitment purposes set out in the Policy; and
• the Candidate Data may be transferred worldwide consistent with the Policy.

Your consent is required in order to complete the submittal process. In order to continue, you must click actively on the x in the consent box. By clicking the consent box you are hereby consenting and agreeing that you are freely providing the information required for the application process.

This Policy does not form part of any contract of employment offered to successful hires.

Contact details

If you have any questions or complaints in relation to the use of your personal information, or this Notice, you can contact our Data Protection Officer at [email protected] or [email protected].

Scope

This Policy applies to all BRG Group entities that process Candidate Data.

Processing refers to any action that is performed on Candidate Data, whether in whole or in part by automated means, such as collecting, recording, organizing, storing, modifying, using, disclosing, or deleting such data.

Candidate Data is defined as any identifiable information about you that you or someone else provides on your behalf in the context of applying for a position with a BRG Group entity.

This Policy does not cover data rendered anonymous or where pseudonyms are used. Data is rendered anonymous if individual persons are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost, or labor. The use of pseudonyms involves the replacement of names or other identifiers with substitutes, so that identification of individual persons is either impossible or at least rendered considerably more difficult. If Data rendered anonymous becomes no longer anonymous (i.e., individual persons are again identifiable), or if pseudonyms are used and the pseudonyms allow identification of individual persons, then this Policy will again apply.

Application of Local Laws

This Policy is designed to provide a uniform minimum compliant standard for every BRG Group entity with respect to its protection of Candidate Data worldwide. BRG Group recognizes that certain laws may require stricter Policy than those described in this Policy. Each BRG Group entity will handle Candidate Data in accordance with local law applicable at the place where the Candidate Data is processed.

Where applicable local law provides a lower level of protection of Candidate Data than that established by this Policy, then the requirements of the Policy shall apply.

Principles for Processing Candidate Data

BRG Group respects the privacy rights and interests of each individual. Each BRG Group entity will observe the following principles when processing Candidate Data:

• Data will be processed fairly and lawfully.
• Data will be collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes.
• Data will be relevant to and not excessive for the purposes for which they are collected and used. For example, Data may be rendered anonymous when feasible and appropriate, depending on the nature of the Data and the risks associated with the intended uses.
• Data will be accurate and, where necessary, kept up-to-date.
• Reasonable steps will be taken to rectify or delete Candidate Data that is inaccurate or incomplete.
• Data will be kept only as long as it is necessary for the purposes for which it was collected and processed.
• Data will be processed in accordance with the individual’s legal rights (as described in these Policy or as provided by law).
• Appropriate technical, physical, and organizational measures will be taken to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to Data.

Data Collection

You may use various methods to submit your Candidate Data to BRG Group. These methods may include: (a) e-mail or paper submission to BRG Group personnel; (b) online submittal of Candidate Data processed by a third-party service provider into an electronic database based in UK accessible by BRG Group authorized personnel; or (c) via a BRG Group employment application.

BRG Group may periodically collect further information with your consent or in accordance with applicable laws. For example, BRG Group may collect your feedback and opinions (e.g., surveys) for business purposes, such as improving processes. You may respond to these surveys voluntarily or may elect not to respond and will not suffer reprisals for your decision. This Policy will be applicable to any further information collected including any responses to such surveys.

Purposes and Access for Candidate Data Processing

Each BRG Group entity processes Candidate Data for legitimate human resources purposes. Such processing will be conducted within such purpose limitations and in accordance with applicable law.

These principal purposes include: Identifying and/or evaluating candidates for BRG Group positions; making a decision about whether the individual should be hired; maintaining appropriate record-keeping related to hiring practices; analyzing the hiring process and outcomes; and conducting background investigations, where permitted by law (the “Purposes”).

If a BRG Group entity processes your Candidate Data for purposes that go beyond the Purposes described above, such BRG Group entity responsible for the new purpose will ensure that you are informed of the new purposes for which your Candidate Data is to be used, and the categories of recipients of your Candidate Data.

Your Data will be accessed and processed by individuals who are involved in the hiring process for BRG Group and who have a legitimate need to access and process your Data for the Purposes.

Types of Candidate Data

The types of Candidate Data processed includes such as:

• Candidate status
• Work history/job data
• Education Compensation
• Employer feedback
• Online questionnaire results
• Candidate contact information
• Previous addresses or names of the Candidate
• Additional information provided by the Candidate (e.g., a cover letter)
• Driver’s license number, as needed for certain positions
• References
• Criminal history, where permitted by law

Special Categories of Data

To the limited extent a BRG Group entity needs to collect any Special Data (such as data containing personal information about racial or ethnic origin, political opinions, religious or political beliefs, trade-union membership, health or medical records, or criminal records), such BRG Group entity will ensure that the individual is informed of such collection and processing. Where required by law, the person’s explicit consent to the processing and particularly to the transfer of such data to non-BRG Group entities will be obtained. Appropriate security and protection measures (e.g., physical security devices, encryption, and access restrictions) will be provided depending on the nature of these categories of data and the risks associated with the intended uses.

Security and Confidentiality

Each BRG Group entity is committed to taking appropriate technical, physical, and organizational measures to protect Candidate Data against unauthorized access, unlawful processing, accidental loss or damage and unauthorized destruction.

Equipment and Information Security

To safeguard against unauthorized access to Candidate Data by third parties outside BRG Group, all electronic Candidate Data held by BRG Group entities are maintained on systems that are protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding Candidate Data are “backed up” (i.e., the data are recorded on separate media) on a regular basis to avoid the consequences of any inadvertent erasure or destruction of data. The servers are stored in facilities with comprehensive security and fire detection and response systems.

Access Security

Each BRG Group entity limits access to internal systems that hold Candidate Data to a select group of authorized users who are given access to such systems through the use of a unique identifier and password. Access to Candidate Data is limited to and provided to individuals for the purpose of performing their job duties (e.g., a human resources manager may need access to a Candidate’s contact information for the purposes of setting up an interview). Compliance with these provisions will be required of third-party administrators who may access certain Candidate Data, as described in the Transferring Data section.

Training

BRG Group will conduct training regarding the lawful and intended purposes of processing Candidate Data, the need to protect and keep information accurate and up-to-date, and the need to maintain the confidentiality of the Data to which employees have access. Authorized users will comply with this Policy, and each BRG Group entity will take appropriate disciplinary actions, in accordance with applicable law, if Candidate Data are accessed, processed, or used in any way that is inconsistent with the requirements of this Policy.

Rights of Data Subjects

Any person may inquire as to the nature of the Candidate Data stored or processed about him or her by any BRG Group entity.

You will be provided access to Candidate Data as is required by law in your home country, regardless of the location of the data processing and storage. A BRG Group entity processing such data will cooperate in providing such access either directly or through another BRG Group entity.

If any Candidate Data is inaccurate or incomplete, you may request that the data be amended by submitting a new resume/CV with the updated information (e.g., new home address or change of name).

If you demonstrate that the purpose for which the data is being processed is no longer legal or appropriate, the data will be deleted, unless the law requires otherwise. All personal information will be deleted as required by regional data privacy laws and regulations.

You have the ability to access information we hold about you and to update, correct or erase (the extent allowed by applicable law) your account information at any time by logging into your account.

Alternatively, you may complete and submit a Data Subject Request Form.

Please see for more details also our Privacy Notice. You may also contact the Human Resource Manager at the relevant BRG Group entity to ask questions regarding this Policy or your Candidate Data or withdraw your consent.

Transferring Data

Transfers to other BRG Group entities

BRG Group strives to ensure a consistent and adequate level of protection for Candidate Data that is processed and/or transferred between BRG Group entities. A transfer of Candidate Data to another BRG Group entity is considered a transfer between two different entities, which means that even in such “intra-group” cases, a data transfer shall be carried out only if applicable legal requirements are met and if:

• The transfer is based on a clear business need;
• The receiving entity provides appropriate security for the data;
• The receiving entity ensures compliance with this Policy for the transfer and any subsequent processing.

Transfers to non-BRG Group entities

At times, BRG Group may be required to transfer Candidate Data to selected external third parties that they have hired to perform certain employment-related services on their behalf. These third parties may process the data in accordance with the BRG Group’s instructions or make decisions regarding the data as part of the delivery of their services. In either instance, BRG Group will select reliable suppliers who undertake, by contract or other legally binding and permissible means, to put in place appropriate security measures to ensure an adequate level of protection. BRG Group will require external third-party suppliers to comply with these Policy or to guarantee the same levels of protection as BRG Group when handling Candidate Data. Such selected third parties will have access to Candidate Data solely for the purposes of performing the services specified in the applicable service contract. If BRG Group concludes that a supplier is not complying with these obligations, it will promptly take appropriate actions.

BRG Group may be required to disclose certain Candidate Data to other third parties (1) as a matter of law (e.g., to tax and social security authorities); (2) to protect BRG Group’s legal rights (e.g., to defend a litigation suit); or (3) in an emergency where the health or security of a Candidate is endangered (e.g., a fire).

Direct Marketing

BRG Group will not disclose Candidate Data outside BRG Group to offer any products or services to a Candidate for personal or familial consumption (“direct marketing”) without his or her prior consent.

The restrictions in this section apply only to contact data obtained in the context of applying for a position with BRG Group. They do not apply to contact data obtained in the context of a consumer or customer relationship.

Enforcement Rights and Mechanisms

Each BRG Group entity will ensure that this Policy is observed. All persons who have access to Candidate Data must comply with this Policy. In some countries, violations of data protection regulations may lead to penalties and/or claims for damages.

If at any time, a person believes that Candidate Data relating to him or her has been processed in violation of this Policy, he or she may report the concern to the Data Protection Officer. The Data Protection Officer may be contacted by email at [email protected] or [email protected]. The processes described in this Policy supplement any other remedies and dispute resolution processes provided by BRG Group and/or available under applicable law.

Audit Procedures

To further ensure enforcement of this Policy, BRG Group’s Data Protection Officer will audit compliance of this policy from time to time to ensure compliance with this Policy. In the event the Data Protection Officer determines that there are matters that cannot be adequately handled with BRG Group’s own resources, BRG Group will appoint an independent third party to conduct an investigation/audit of any procedures or issues involving Candidate or employment Data under the Policy.

Communication About the Policy

BRG Group will communicate this Policy to current and new employees by posting them on selected internal BRG Group web sites and by providing a link to the Policy, where Candidate Data are collected or processed.

Obligations Toward Data Protection Authorities

BRG Group will respond diligently and appropriately to requests from data protection authorities about this Policy or compliance with applicable data protection and privacy laws and regulations. BRG Group employees who receive such requests should contact the Data Privacy Officer. BRG Group will, upon request, provide data protection authorities with names and contact details of relevant contact persons.

With regard to transfers of Candidate Data between BRG Group entities, the importing and exporting BRG Group entities will (i) co-operate with inquiries from the data protection authority responsible for the entity exporting the data, and (ii) respect its decisions, consistent with applicable law and due process rights.

Addendum

Rights and Obligations with Respect to Candidate Data Collected within the EU/EEA/UK and Processed Elsewhere.

In addition to any rights and obligations that are set forth in this Candidate Data Protection Policy or that otherwise exist, the following principles established in light of the General Data Protection Regulation (GDPR) will apply to Candidate Data collected by BRG Group entities in the European Union/European Economic Area and processed elsewhere. In jurisdictions where this Addendum applies, the enforcement rights and mechanisms mentioned in the Policy also apply to the provisions of this Addendum. The following are not intended to grant employees further rights or establish further obligations beyond those already provided under the European GDPR:

1. Any transfer of the applicants’ personal data to a third country may take place according to Art. 45 GDPR. BRG Group ensures that the level of protection of natural persons guaranteed by the GDPR is not undermined.

2. If any of the terms or definitions used in the Policy are ambiguous, the definitions established under applicable local law within the relevant EU/EEA member state shall apply or where there are no such definitions under applicable local law, the definitions of the European Data Protection Directive shall apply.

Changes to this Policy

We may change this policy from time to time. We will post any changes to this policy on this page. Each version of this policy is identified at the bottom of the page by its effective date.