WHAT IS THE PURPOSE OF THIS DOCUMENT?
This policy was last modified: 1st of January 2023.
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
The information you have provided to us in your curriculum vitae and cover letter.
The information you have provided on our application form, using Apply with LinkedIn on Partner Sites, such as name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, etc.
Any information you provide to us during the interview.
We may also collect, store and use the following types of more sensitive personal information:
Information about your health, including any medical condition, health and sickness records (if applicable and based on a legal obligation).
Information about criminal convictions and offences (if applicable to the job post).
Information about your salary expectations or your current salary, if this information is shared by you.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
You, the candidate.
Recruitment agency, from which we collect the following categories of data. (Contact information, resume including work experience and history, salary information (current and/or expectations) notice period and availability.)
Your named referees, from whom we collect the following categories of data. (Contact information, resume including work experience and history, notice period and availability.)
Data from third parties if shared with us or from a publicly accessible source. (Contact information, resume including work experience and history, salary information (current and/or expectations) notice period and availability.)
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
Assess your skills, qualifications, and suitability for the role.
Reference checks, where applicable.
Communicate with you about the recruitment process.
Keep records related to our hiring processes.
Comply with legal or regulatory requirements.
It is in our legitimate interest to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that job post.
We also need to process your personal information to decide whether to enter into an employment contract with you.
Having received your CV and cover letter or your application form and the results from the test which you took (if applicable to the job post), we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and/or any other check (if applicable) before confirming your appointment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with the relevant details, we will not be able to take your application further.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We envisage that we might process information about criminal convictions for certain previously defined job posts.
We will collect information about your criminal convictions history if we would like to offer you that previously defined role.
We are entitled to carry out criminal records checks in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role or in case we are legally required to carry out criminal records checks and the role requires a high degree of trust and integrity.
We have in place all appropriate safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application, for example search consultancy, government or other law enforcement authorities (if obliged to share the data with them or is prudent form us to do so), or other entities in the Aleph Group of companies. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information - on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will retain your personal information for a period of three months (or different period, if legally required by the local legislation) after we have communicated to you our decision not to appoint you to the role. We will retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further job opportunity may arise in future and we may wish to consider you for that, we will seek your explicit consent to retain your personal information for a fixed period on that basis.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a »data subject access request«). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). This right cannot be exercised if the processing of your personal data continues to be necessary for the fulfilment of our legal obligations and for determining, enforcing or defending our legal claims.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact your recruiter in writing or address your request at [email protected] or [email protected].
RIGHT TO WITHDRAW CONSENT
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact your recruiter or [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
GLOBAL DATA PROTECTION OFFICER