Privacy Policy

The Hiring Advisors LLC EEA Recruitment Privacy Notice EUROPEAN ECONOMIC AREA (“EEA”) RECRUITMENT PRIVACY NOTICE

Scope of privacy notice
This Recruitment Privacy Notice (“Notice”) only applies to individuals who apply or have applied to work for or be considered for employment by The Hiring Advisors LLC or one of its clients. This Notice explains the type of information we process, why we are processing it and how that processing may affect you.

What do we mean by “personal data” and “processing”?
Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you. “Processing” means doing anything with the data. For example, it includes collecting it, holding it, disclosing it or deleting it. Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by EU privacy law to be “sensitive personal data”.

Your personal data
We process your personal data for the purposes of fulfilling our recruitment practices. Some of the personal data that we process about you comes from you. For example, you tell us your contact details. Other personal data about you is generated from references and third-party companies such as recruitment agencies or provided personal referrals. Your personal data may be seen internally by managers, administrators and associates.

How long do we keep your personal data?
If you are successful in your application your data will be kept on your personnel file. If you are unsuccessful, your data will normally be destroyed or anonymized within twenty-four months after you have been informed that you were unsuccessful, unless you have consented to, or we have some other lawful processing basis for keeping your data for a longer period. Data such as CCTV images may be deleted after a short period.

Contact details
In processing your data, we, and in some cases our clients, may act as a data controller. If you have questions, please contact us at info@thehiringadvisors.com

Legal grounds for processing personal data What are the grounds for processing?
Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts, more than one ground applies. Two of those grounds can be summarized as Legal Obligation and Legitimate Interests. We outline what those terms mean below:


Term : Legal obligation
Ground for processing :Processing necessary to comply
Explanation: Ensuring we perform our legal and regulatory obligations. For  example, providing a safe place of work and avoiding unlawful discrimination.


Term : Legitimate Interests
Ground for processing :Processing necessary for our or a third party’s legitimate interests.
Explanation: Ensuring we perform our legal and regulatory obligations. For  example, providing a safe place of work and avoiding unlawful discrimination.


Term : Consent
Ground for processing :  You have given specific consent to processing your data
Explanation:  data in connection with employment is not conditional on your consent. But there may be occasions where we do specific things such as background screening based on your consent.


Processing sensitive personal data If we process sensitive personal data about you (to the extent permitted by applicable law), as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one of the grounds for processing sensitive personal data applies, including (for example) that the processing is for equality and diversity purposes to the extent permitted by law.

Further information on the data we process and our purposes Examples of the data and the grounds on which we process data are in the table below. The examples in the table cannot, of course, be exhaustive.      

 


Purpose :  Recruitment
Examples of personal data : we may make to verify information provided or background checks (if permitted by law) and any information connected with your right to work. If relevant, and to the extent permitted by law, we may also process information concerning your health, any disability and in connection with any adjustments to working arrangements.
Grounds for processing: Legal obligation legitimate interest consent


Purpose : Contacting you or others on your behalf
Examples of personal data : Your address and phone number, emergency contact information and information on your next of kin.
Grounds for processing: Legitimate interests


Purpose :Security
Examples of personal data : CCTV images
Grounds for processing: Legal obligation, Legitimate interests


Purpose : Monitor diversity & legitimate interest opportunities.
Examples of personal data : Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age
Grounds for processing: Legitimate interests


 

Who gets to see your data?

Internal use

Your personal data may be disclosed to for employment, administrative and management purposes as mentioned in this document. We may also disclose this to other members of our group.

External use

We will only disclose your personal data outside the group if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you.

We may disclose your data if it is necessary for our legitimate interests as an organization or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy). We may also disclose your personal data if you consent, where we are required to do so by law and in connection with criminal or regulatory investigations.

 

Specific circumstances in which your personal data may be disclosed include:

  • Disclosure to external recipients of electronic communications (such as emails) which contain your personal data;
  • Disclosure on a confidential basis to a potential buyer of our business or company for the purposes of evaluation — but only if we were to contemplate selling;
  • Disclosure for purposes of background screening (to the extent permitted by applicable law) & checking or obtaining country specific work authorization;
  • Disclosure for purposes of arranging travel or sending/receiving deliveries; and/or
  • Disclosure for purposes required by applicable law, such as tax withholding reporting or responding to subpoenas.

 

Access to your personal data and other rights

We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.

You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including a description and copy of the personal data and an explanation of why we are processing it.

If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. You may also have the right to be given your data in a machine-readable format for transmitting to another data controller though this right is unlikely to be relevant to you the context of our recruitment processes.

We are unlikely to rely on consent as a ground for processing. However, if we do, you may withdraw consent at any time — though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.

Complaints

If you have complaints relating to our processing of your personal data, you should raise these with Legal in the first instance.

You may also raise complaints with the statutory regulator in your jurisdiction. The relevant statutory regulators are:

In the United Kingdom The Information Commissioner’s Office: https://ico.org.uk

In Germany (in Bavaria) Bayerischen Landesamt für Datenschutzaufsicht: https://www.lda.bayern.de

In France The CNIL: https://www.cnil.fr/fr

In the Netherlands The Autoriteit Persoonsgegevens: https://autoriteitpersoonsgegevens.nl

In Sweden Datainspektionen: https://www.datainspektionen.se

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