Privacy Policy

The Twinings group of companies (“we”, “us”) is committed to protecting and respecting your privacy. This Privacy Notice sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes and events. 
Depending on your location, the company identified as the recruiting Twinings company is responsible for processing your personal data.

 We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions
If your application for employment is successful, a different privacy notice will be communicated to your separately. 

Your Personal Information

Information we collect from you
We collect and process some or all of the following types of information from you in connection with our recruitment processes:
  • Information that you provide when you apply for a role or attend one of our events. This includes information provided through an online application, via email, in person at interviews and/or by any other method. In particular, we process personal details such as name, email address, address, date of birth, qualifications, experience, and any information relating to your employment history, skills and experience that you provide to us. 
  • If you contact us, we may keep a record of that correspondence. 
  • Details of your visits to our careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access. 
Information we collect from other sources
We may receive information about you from recruitment agencies we work with, your referees or previous employers, or from publicly available sources in the course of pre-employment checks (where relevant).
 
Pinpoint also provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles. 

Pinpoint’s technology enables us to search various databases, which may include your personal data, to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.

Uses made of your information

Lawful basis for processing
The main purpose of our website is to provide information on working life at our company and for candidates to apply for a role, either a current vacancy or to send a CV to our Talentpool. We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are the recruitment of staff for our business. 

How do we use this information? 
We use your information for the following purposes:
  • finding appropriate candidates to fill our job openings;
  • considering your application and assessing your suitability for open roles;
  • communicating with you in relation to the recruitment process;
  • conducting eligibility and pre-employment background checks (where local law requires and/or permits this); and 
  • for equal opportunities purposes, including for aggregated and anonymised reporting.
 We use your data for the purpose of our legitimate interests in managing our recruitment process and so that we can take steps at your request prior to entering into a contract. 

Where necessary, we will also use this data for the purpose of our legitimate interests in accessing appropriate professional advice and in order to ensure we comply with legal obligations to which our business is subject.
 
We may also rely on your consent to collect and use your personal data in certain situations where allowed by local laws. Where we rely on your consent to collect and use such information, you are not obliged to provide your consent and you may choose to subsequently withdraw your consent at any stage once provided.

When you apply for a position with us or submit information in support of your application, we will highlight whether the information we are requesting is essential so that we can progress your application or whether the supply of this information is optional. Optional information includes gender, gender identity, sexual orientation, age brackets, disability, ethnicity and pronouns.
 
Particularly sensitive personal information
Where appropriate we will use your particularly sensitive personal information in the following ways: 
  • We use information about disability to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview. We process this data to carry out our obligations and exercise specific rights in relation to employment; 
  • We use information about racial or ethnic origin, religious or philosophical beliefs, disability and/or sexual orientation to ensure meaningful equal opportunity monitoring and reporting;
  • Any information we ask you to supply in relation to past criminal offences will be held by us only in accordance with your consent (unless the supply of this information is required by law because of the nature of the role you are applying for). If a position that is, or may be, of interest to you requires background checks, we will highlight this to you. 
Automated Decision making / profiling
In some instances, we may process your information using automated means. In particular,  we may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider based on criteria we have identified. However we will not make decisions about you based solely by automated means, meaning we will always involve humans in the decision-making process.

How we store your personal data

Security
We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in any unauthorised way. We limit access to your personal data to those who have a genuine business need to view it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
 
 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
 
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where we store your personal data
The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes.   
 
Where we transfer personal information to countries other than the country where the data was originally collected, we will ensure an adequate degree of protection is afforded to your personal information by ensuring that:
  • We transfer personal data to countries that have been deemed adequate; or 
  • We have put in place appropriate safeguards, such as data transfer agreements approved by the European Commission, UK or local data protection regulator, as appropriate,  
Where necessary, we may implement additional technical, organizational or contractual measures to ensure an adequate level of protection for your personal information. Where required, further information concerning these safeguards can be obtained by contacting us at the details provided below.

How long we keep your personal data
We retain all candidate data for a period of 48 months from the time of application. Your personal information will be deleted on one of the following occurrences:
  •  Deletion of your personal information by you via the Manage Your Data tool or 
  •  Receipt of a written request by you to us. 
Who do we share this information with? 
We take care to ensure your data is only processed where this is necessary and for the purposes described above. Your personal data may be shared with members of our HR team, hiring managers and other individuals with a need to know the information or who are participating in the recruitment process you are taking part in.

Other companies in the Twinings group of companies may need to process your personal data (normally, the Twinings company where you apply for a role will process your personal data as an independent data controller).
 
We may share your personal data with third parties who process data on our behalf, including where external recruitment agencies assist us with recruitment or IT service providers that store data on our behalf. We use Pinpoint as our provider for recruitment activities, which securely stores your personal data for us.
 
We may also share your personal data with external providers who carry out pre-employment checks, where necessary.
 
If necessary for our exercise or defence of legal claims, we may also share your personal data with our insurers or professional advisors.
 
Otherwise we will not share your information with any third party unless:
  • We have your permission;
  • We are required to do so by law (e.g. with courts or law enforcement authorities);
  • This is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
  • This is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).

Your Rights 

You have a number of important rights in relation to your personal data. In summary, those include rights to: 
  • Request access your personal data and to certain other supplementary information that this Privacy Notice is already designed to address 
  • Request that we correct any mistakes in your information which we hold 
  • Request the erasure of personal data concerning you in certain situations 
  • Request access to the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations 
  • Object to processing of personal data concerning you in certain situations 
  • Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you 
  • Otherwise ask us to restrict our processing of your personal data in certain circumstances (Where we process your data on the basis of your consent) to withdraw your consent at any time
If you would like to exercise any of those rights, please either:
  •  Utilise the Manage Your Data tool provided or 
  •  Contact us using our contact details below, ensuring we have enough information to identify you, proving your identity and address and confirming which information to which your request relates 

How to complain

We hope that we can resolve any query or concern you raise about our use of your information. Questions, comments or requests concerning this privacy notice are welcomed and should be addressed to  Recruitment@twinings.com 

You can also lodge a complaint with your local data protection authority. If you reside in the UK, this is the Information Commissioner’s Office. If you reside in the EU, you can find out your local data protection authority at this link.   

This privacy notice was last updated April 2025.