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Job Applicant Privacy Notice
The organisation as a controller
As part of any recruitment process, Thunderful (we, the organisation) collects and processes personal data relating to job applicants. In this Privacy Notice we are referring to the relevant company in the organisation responsible for processing your personal data (the data controller). This is the entity to which your application has been made. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the organisation collect?
The organisation collects a range of information about you. This includes:
● your name, address and contact details, including email address and telephone number;
● details of your qualifications, skills, experience, and employment history;
● information about your current level of remuneration, including benefit entitlements;
● whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process; and
● information about your entitlement to work in the specific country in which you will operate.
The organisation collects this information in a variety of ways. For example, data might be contained in application forms, CVs, portfolios or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
The organisation may also collect personal data about job applicants from publicly available sources – such as a job applicant’s bio or LinkedIn profile.
Why does the organisation process personal data?
The organisation needs to process data to take steps at your request prior to entering a contract with you. It also needs to process your data to actually enter into a contract with you.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work, before employment starts.
The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom
to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
The organisation processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise.
The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment.
The organisation will not transfer your data outside the European Economic Area.
How does the organisation protect data?
The organisation takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does the organisation keep data?
If your application for employment is unsuccessful, the organisation will hold your data on file for 12 months after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file, the organisation will hold your data on file for a further 12 months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted or destroyed unless you provide further consent for your personal data to be held longer.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a staff privacy notice.
As a data subject, you have a number of rights. You can:
● access and obtain a copy of your data on request;
● require the organisation to change incorrect or incomplete data;
● require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
● object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
● ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact the recruiting manager for further guidance.
Please be aware that the above rights are qualified and there may be circumstances where the organisation is unable to comply with all or part of a request.
If you believe that the organisation has not complied with your data protection rights, you can complain to the national data protection supervisory authority in your country, although we would ask that you contact us in the first instance to resolve any issues.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
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