PGA European Tour ("the Company"), “we,” “us”) has issued this Privacy Notice ("Notice") to job candidates this Notice may apply to ("you", "your"). This Notice sets out the personal information that we collect and process about you in connection with your application to join the Company (your “Application”), the purposes of such processing and the rights that you have in connection with the collection and processing of your personal data. Other privacy notices may also apply to you where you interact with the Company in other capacities (for example, as a visitor to the Company’s website).
The Company takes your privacy seriously and we are committed to protecting your personal information and managing it in accordance with applicable law. If you are in any doubt regarding the applicable standards, or have any questions about this Notice, please contact dataprotection@etghq.com.
Legal Basis for Processing
We process candidate personal data based on:
Taking steps to enter employment contract (Article 6(1)(b)): Core recruitment activities
Legal obligations (Article 6(1)(c)): Right to work checks, equality monitoring.
Legitimate interests (Article 6(1)(f): Assessing suitability, preventing fraud, maintaining candidate pool.
Consent (Article 6(1)(a): Retaining details for future opportunities (optional)
For special category data:
Employment law obligations (Article 9(2)(b)): Reasonable adjustments, equality monitoring
Substantial public interest (Article 9(2)(g)): Equality of opportunity monitoring per Equality Act 2010
Explicit consent (Article 9(2)(a)): Optional diversity monitoring
1.Types of personal information we collect about job candidates.
As part of your application, we may process personal information about you and your family members and other individuals whose personal information has been provided to us.
We collect different information at various stages:
Application Stage:
Name, contact details, CV, letter covering, qualifications, work history, references.
Assessment Stage:
Interview notes, assessment results, work samples.
Pre-employment (successful candidates only):
Right to work documents, bank details, emergency contacts, medical information relevant to role, DBS checks (specific roles only)
The types of personal information we process include, but are not limited to:
Identification data e.g., name, photograph, gender, date of birth, employee number.
Contact details e.g., home address, telephone/email, emergency contact details.
Employment details e.g., job title/position, office location, and holiday records.
Professional qualifications achievements and skills information e.g., academic/professional qualifications, education, CV, languages.
National identifiers e.g., national ID/passport, immigration status, driver's license, social security numbers.
Family members (or person nominated as next of kin) information – such as names, relationship to you, contact details.
Financial information e.g., bank account details, tax information, salary, and company allowances.
Benefits and pension information e.g., employer pensions contributions, pension entitlements, retirement information (if applicable), life assurance, and private medical cover information.
Medical information, e.g., Medical Details disclosures, Occupational Health Assessments, fitness for work assessments, Covid-19 Testing
Travel and accommodation information within and outside the UK for business.
Health and safety information e.g., records of accidents at work, and
Criminal records / Disclosure and Barring Service (DBS) checks.
Criminal Records Processing
DBS checks are only conducted where proportionate and relevant to the role:
Standard checks: Roles with financial responsibilities or regulatory requirements
Enhanced checks: Roles involving work with children or vulnerable adults.
Processing is under Schedule 1, Part 1, Paragraph 1 of the Data Protection Act 2018 (employment purposes). Our criminal records policy details which roles require checks and are available from HR.
2. Source of Personal Information
Usually, you will have provided the information we hold about you but there may be situations where we collect personal information from other sources. The followingare the types of information we may collect about you and the source of the information:
Sources of personal information
References from nominated third party referees; and
Feedback from colleagues, including managers and peers collected during performance conversations, development of any performance improvement plans and/or in the creation of any disciplinary records.
Background screening providers (for relevant roles)
Publicly available sources including professional networks (LinkedIn), company websites.
Recruitment agencies acting on our behalf.
Educational institutions for qualification verification
Professional bodies for registration/membership verification
Previous employers beyond nominated referees (with your consent)
3. Purposes for processing personal information
The Company collects and uses your personal information primarily for the purpose of managing your Application – for example, your employment contract and employment records (to manage your employment with us), your bank account and salary details (so we can pay you), medical information to aid risk assessments and Personal Emergency Evacuation Plans (PEEPs), and details of your dependents (for emergency contact and benefits purposes).
We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently – for example, for IT security/management, accounting purposes, or financial planning. We may also process your personal information to investigate breaches of law or of our own internal policies.
We may also use your personal information where we consider it necessary for complying with laws and regulations, including collecting and disclosing candidate personal information as required by law (e.g., for tax, health and safety, anti- discrimination laws), under judicial authorisation, or to exercise or defend the legal rights of the Company and its affiliate entities.
4. Monitoring
The Company will carry out automated monitoring of its IT and communications systems through automated tools such as anti-malware software, website filtering, and spam filtering. It will also conduct monitoring of its physical premises, for example by using CCTV and security badges.
The primary purpose of this monitoring is to protect the Company, its employees, prospective employees, customers, and business partners, for example:
for general network operation and security, including the security of the Company’s IT systems and assets, and the optimal operation of its network and devices.
for proof of business transactions and archiving.
for coaching, training, and evaluation of employees.
for the protection of confidential information and intellectual property.
for investigating breaches of internal policies, fraud or other unlawful or wrongful activity, or to respond to a particular personnel or company incident.
for business continuity (such as monitoring business-related emails following an employee's departure); and
for physical security of its premises.
5. Who we share your personal information with
The Company takes care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the confidentiality and integrity of the information is maintained.
We will share your personal information with other members of the Company’s group of companies (including other branches) around the world to administer human resources, as well as for other legitimate business purposes (such as IT services/security, tax & accounting purposes, general business management).
We make certain personal information available to third parties who provide services to us. We do so on a "need-to-know basis" and in accordance with applicable data protection law.
We may also disclose personal information to other third parties on other lawful grounds, including:
to comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, or to meet national security or law enforcement requests, including, but not limited to, a subpoena or search warrant.
with your consent.
as necessary to establish, exercise or defend against potential, threatened or actual litigation.
where necessary to protect the vital interests of another person; and
in connection with the sale, assignment or other transfer of all or part of our business.
6. Transfer of your personal information outside of Europe
As the Company operates at a global level, we may need to transfer personal information to other countries. Transfers may also need to be made to other countries where we operate (such as information on relevant experience you may have for a particular job or secondment). When we export your personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws and legislation.
Likewise, when we use third party service providers and their services involve transfers of personal information outside of the European Economic Area or the United Kingdom, we ensure that the third-party service provider has appropriate data transfer mechanisms in place such as Standard Contractual Clauses to enable the transfer.
7. Retention policy
Personal data is retained for:
Unsuccessful candidates:
6 months from decision
12 months if you consent to join talent pool.
Successful candidates:
Recruitment records transferred to employee file
Retained for employment duration plus 6 years.
Interview notes and assessments:
6 months for unsuccessful candidates
3 years for successful candidates (performance review purposes)
8. Your rights as a data subject
At any point while we hold your personal information, you have a number of rights available to you, including the following:
Right of access – you have the right to access a copy of the information that we hold about you and to obtain information about how we process it.
Right of rectification – you have a right to request that we correct data that we hold about you if it is inaccurate or incomplete.
Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply you have a right to request that we restrict the processing of your information.
Right of portability – you have the right to have the data we hold about you provided to you in an electronic format and/or to request that it is transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing; and
Right to object to automated processing – you also have the right not to be subject to a decision based solely on automated processing which adversely affects your legal rights.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time (by contacting us using the contact details set out in section 10 below). This will not, however, affect the lawfulness of the processing before your consent has been withdrawn.
You can exercise these rights in the first instance using the contact details set out in section 10 below. We will advise you promptly if we require further information to fulfil your request. Please be aware that these rights are, in the most part, not absolute and are subject to exceptions; for example, if we have a necessary and lawful basis on which to continue processing your personal data, we may refuse your request to delete it.
9. Updates to this Notice
We may amend this Notice from time to time to keep it up to date with legal requirements, best practice, and/or the way we operate our business. We will update this policy on the Candidate Home section of the corporate website and indicate at the end of the Notice when it was most recently updated. We encourage you to check back on this Notice periodically so that you are aware of the most recent version of it.
Where such changes will materially affect your privacy rights, we will also inform you about such changes via email.
10. Questions, comments and how to contact us.
In the first instance, you may wish to raise any general questions or concerns with your line manager.
Please address any questions or requests relating to this Notice to dataprotection@etghq.com , or alternatively by post to:
Data Protection OfficerEuropean TourWentworth DriveVirginia Water Surrey GU25 4LX You have a right to lodge any complaints with the Information Commissioner's
Office although we ask that you raise any issues internally in the first instance with our Data Protection Officer at dataprotection@etghq.com
