Legal bases for processing
Data protection law requires us to explain the legal reasons why we use your personal data. Because this Notice applies to candidates in the EEA and the UK, the legal basis we rely on may vary depending on the recruitment activity, the type of personal data involved and the country in which you apply.
In most cases, we process your personal data because:
- it is necessary to take steps at your request prior to potentially entering into an employment contract with you (for example, assessing your application and progressing you through the recruitment process);
- it is necessary for us to comply with a legal obligation (for example, carrying out right to work checks or responding to regulatory requests);
- it is necessary for our legitimate interests in managing and improving our recruitment processes, including reviewing applications, assessing candidate suitability, communicating with applicants, and ensuring the effectiveness and fairness of our recruitment activities, provided that those interests are not overridden by your rights and interests;
- in limited circumstances, where required by law or where the processing is genuinely optional, we rely on your consent. Where we rely on consent, you can withdraw it at any time without detriment;
- where we use automated decision-making in recruitment, the lawful basis we rely on depends on the location of the candidate, the applicable data protection law and the recruitment process in which the automated decision-making is used.
For candidates in the UK, where we use automated decision-making that has legal or similarly significant effects on you, we rely on our legitimate interests in operating an efficient, consistent and objective recruitment process, including the use of technology to assess candidate suitability, provided that these interests are not overridden by your rights and freedoms. We carry out a legitimate interest assessment to ensure that this processing is necessary and proportionate and that appropriate safeguards are in place.
For candidates in the EEA, where we use solely automated decision-making that produces legal or similarly significant effects, and applicable data protection law requires a specific basis for that processing, we do not rely on legitimate interests. Instead, we rely on the fact that the processing is necessary to take steps at your request prior to potentially entering into an employment contract with you, or, where appropriate, your consent.
Where we rely on consent for such processing, this will only be used where it is freely given and genuinely optional, and you will not suffer any detriment if you choose not to provide or withdraw your consent.
Where relevant, you will be informed about the use of automated decision-making and your associated rights, including the right to request human intervention, to express your point of view, and to contest the decision.
Where we process special category personal data as part of recruitment, for example where you require reasonable adjustments or where right to work checks involve biometric data, we will only do so where an additional condition under applicable law applies, and appropriate safeguards are in place.
The table below explains the main legal bases we generally rely on for the processing activities described in this Notice.
| Processing activity |
Main legal basis we generally rely on |
| Profile management including Talent Pools, future opportunities, job alerts, Talent Community communications and optional recruitment marketing |
Legitimate interests, except where consent is required by applicable law |
| Pre-screening |
Legal obligation where required by law, otherwise legitimate interests; and where relevant, an additional condition for special category data |
| Background checks and references |
Legal obligation where required by law, otherwise legitimate interests |
| Adjustments and accommodations |
Legal obligation where required by law, otherwise legitimate interests; and where relevant, an additional condition for special category data |
| Diversity and equal opportunity monitoring |
Legal obligation, where applicable, together with an applicable additional condition for special category data, such as obligations in the field of employment and social protection law, substantial public interest, or, where those grounds do not apply and consent is appropriate, explicit consent |
| Candidate Evaluation (including Candidate Assessment, Candidate Digital Interview Recording, Candidate Personal Interview, Engagement Centre, Interview and Assessor Feedback, and Candidate Review and Shortlisting) |
Legitimate interests, and in some cases taking steps at your request before entering into a contract |
| Candidate sourcing, rediscovery and referral |
Legitimate interests and in some cases consent where required by applicable law |
| Security and fraud prevention |
Legitimate interests, and where applicable legal obligation |
| Candidate Ranking |
Legitimate interests |
| Communication |
Legitimate interests, and where appropriate taking steps at your request before entering into a contract |
| Statistical research |
Legitimate interests |
| Data retention |
Legitimate interests, and where applicable legal obligation |
We use the personal data that we collect or obtain about you during the recruitment process for the following purposes:
- Unilever Career Site: We process personal data through the Unilever Career Site to enable you to browse and search for roles, create or access your candidate account and submit applications. We also use tools to answer career-related questions, help you find relevant roles and provide short summaries alongside full job descriptions. Subject to your cookie choices, we may use information about how you interact with the site, such as pages visited, searches made and jobs viewed, to personalise your experience and to operate, secure, improve and report on the site.
- Profile management: We process the personal data in your candidate profile, including your contact details, CV, qualifications, experience, skills, job preferences and location, to create and maintain your account in our recruitment systems. We use your profile to record and manage your applications, recruitment interactions and preferences, assess your suitability for roles you apply for and, where appropriate, identify your profile for relevant future opportunities. You can review and update your profile information and preferences where this functionality is available.
- Talent Communities and recruitment communications: If you join a Talent Community, sign up for job alerts or ask to hear about future opportunities, we use your contact details, profile information, skills, interests, job preferences and location to provide relevant communications. These may include vacancies, recruitment events, Unilever careers information, career-related content and other talent engagement or recruitment marketing opportunities. We may tailor communications to your profile and preferences. Where available, you can update the types of communications you receive and opt out at any time through an unsubscribe option or your candidate profile. Opting out will not affect an active application.
- Pre-screening: We check that you can lawfully enter into a contract and fulfil the essential job criteria, e.g. you have the relevant work authorisation and have answered job-specific screening questions. We may also use a third-party provider to carry out right to work checks, which may include processing identity document information or photographs, where used by the provider and permitted by applicable law, biometric data for that purpose.
- Candidate sourcing and rediscovery: Where relevant to the recruitment process and permitted by applicable law, we may use recruitment tools to identify and surface candidates or potential candidates from existing recruitment systems or talent pools whose experience appears relevant to a role. This helps our recruitment teams consider suitable candidates for current opportunities.
- Background checks and references: Where permitted by applicable law and relevant to the role, we may process personal data to verify information provided in your application, carry out employment history, qualification, identity checks and obtain references. We use this information to assess your suitability for the role, meet legal or regulatory requirements, protect our legitimate interests in operating a safe and reliable recruitment process, and, where applicable, support our decision on whether to offer you employment.
- Adjustments and accommodations: Where relevant, we process personal data, including information about your health or disability, to consider and provide reasonable adjustments or other accommodations during the recruitment process. We use this information to support your participation in assessments, interviews and other recruitment activities, and to help ensure that our recruitment process is accessible and fair.
- Diversity and equal opportunity analysing: Where permitted by applicable law, we may collect and use diversity and equal opportunity information on an optional basis for measuring and reporting purposes. This helps us understand how our recruitment processes are operating, measure progress in attracting diverse talent and support our inclusion and equal opportunity objectives. This information is kept separate from a candidate’s application profile and is not used to make recruitment decisions. This processing may not be carried out where local law does not permit it.
- Security and fraud prevention: We may process personal data to help protect the integrity of our recruitment process, including to detect and prevent the use of unauthorised tools or other activity that could undermine the fairness or lawfulness of applications and assessments.
- Candidate Profile Evaluation: Depending on the type of job opportunity you apply for, you are required to complete one or more of the following steps:
- Candidate Assessment: We use the SOVA online aptitude assessment developed by industrial and organisational psychologists, in line with the Unilever Core Behaviours. Where our Unilever behaviours are changed from time to time, these updates are reflected in the assessments. The assessment helps us evaluate your suitability for the job opportunity you have applied for.
- Depending on the type of role, the assessment may include questions designed to evaluate one or more of the following areas: personality, motivation, cognitive ability, numerical reasoning and verbal reasoning.
- Your responses are scored using a structured, rule-based approach based on predefined psychometric models. Individual question scores are combined to create competency scores. Competency scores are combined to produce an overall assessment score, which the online platform calculates automatically. This scoring process is carried out automatically by the online platform. For early careers programmes, including graduate, leadership internship and other internship programmes, this process will involve automated decision-making, including decisions that have a significant effect on you, such as determining whether your application progresses to the next stage of the recruitment process. For experienced careers / experienced professional recruitment, the assessment result is reviewed together with other relevant information, such as your experience, qualifications, application information and role-specific criteria, and decisions to progress or reject candidates are not based solely on the automated assessment score.
- For early careers programmes, including graduate, leadership internship and other internship programmes, if your overall assessment score does not meet the required threshold, your application will be rejected at this stage, and you will be notified. If your overall score meets the required threshold, you can be considered to proceed to the next stage of the recruitment process. Thresholds are set and adjusted depending on application volumes and role requirements within each recruitment cycle.
- Where automated decision-making is used that has legal or similarly significant effects on you, you will be informed and you have the right to request human intervention, to express your point of view, and to contest the decision. See Automated Decision-making section of this notice below, for more detail.
- Digital Video Interview: If your application is progressed to the next stage, you will be invited to complete a short video interview. This includes a predefined set of questions that you must answer within a set time frame and may include a case study relevant to the role. You will be asked to record your response to each question. This video will be reviewed by Talent Partners, who will make the decision as to whether you progress to the next stage in the recruitment process.
- Engagement Centre: Depending on the role, you will be invited to attend an Engagement Centre, which is a structured assessment stage that may include exercises, interviews, group activities, case studies or presentations. We process the information you provide and our observations from these activities to assess your suitability for the role.
- Candidate Ranking: To support our recruiters in identifying potential candidates, we use Workday HiredScore, an automated tool that evaluates and ranks elements of your profile (such as work experience and qualifications) using natural language processing and machine-learning models. This ranking is used to support shortlisting and does not, by itself, determine the final hiring decision.
- Candidate Personal Interview: If you are invited to a face-to-face interview or a video interview, the interviewer may ask relevant questions to assess your suitability for the role.
- Communication: We may use a chatbot for answering recruitment related queries, sending communications & scheduling interviews.
- Statistical research: We perform general statistical research using your data and data of other candidates to analyse the effectiveness of our selection process and we use aggregated information to create reports. This may include processing session data on online visitor activity.
AUTOMATED DECISION MAKING
Where we use automated decision-making that has legal or similarly significant effects on you, we will provide information about it in this Notice and, where appropriate, at the point of use.
- Candidate Assessment: The online aptitude assessment content and scoring logic have been designed by a team of industrial and organisational psychologists in partnership with Unilever, using Unilever’s competency framework to inform development. The assessment is scored automatically using a structured, rules-based scoring. Your responses are not scored using artificial intelligence (AI) or machine learning techniques. The scoring method does not “learn” from your answers or change over time. This means that the same candidate responses and response times will always generate the same scores. The platform tallies your responses and calculates an overall assessment score. This scoring process is fully automated. For early careers programmes, including graduate, leadership internship and other internship programmes, if your overall assessment score does not meet the required threshold for the role you have applied for, your application will be rejected at this stage, and you will be notified. Thresholds are set in relation to role requirements and are reviewed periodically. For experienced careers / experienced professional recruitment, the assessment result is reviewed together with other relevant information, such as your experience, qualifications, application information and role-specific criteria, and decisions to progress or reject candidates are not based solely on the automated assessment score.
- Your Rights: In the EEA and the UK, if an automated decision is used that has legal or similarly significant effects on you, you have the right to request human intervention, to express your point of view, and to contest the decision. If you wish to exercise any of these rights, you must contact us using this link [Request a Review of Your Assessment Outcome – Fill in form] within seven days from being notified, so that we can consider your request while the recruitment process remains active. A trained reviewer with authority to change the outcome will reconsider the decision, taking into account any additional information you provide. We aim to respond within a reasonable timeframe.
- Candidate CV screening: We use tools that apply natural language processing and machine learning to assess how closely a candidate’s CV and work experience align with the job requirements. The model generates a grade from A to D, which helps our Talent Partners prioritise applications for review. We do not make hiring decisions solely based on these grades. Our Talent Partners review applications and make decisions using human judgement, taking into account your application as a whole (including your experience, skills and performance across other stages of the selection process).
