Aelieve Recruiting Privacy Notice
Last Modified: September 13, 2018
Introduction and scope of privacy notice
This Recruitment Privacy 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 personal 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, like your first and last name, email address, and phone number. Other personal data about you is generated from references and third party companies such as recruitment agencies, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google. Your personal data will be seen internally by managers, administrators and HR. We may also share your data with external law firms for assessment of employment permits and visa options.
During the recruitment process, we try not to collect or process any “Sensitive Personal Information” unless authorized by law or where necessary to comply with applicable laws. Sensitive Personal Information includes the following: information that reveals your racial or ethnic origin, religious, political, or philosophical beliefs, or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health, sex life, or sexual orientation.
How long do we keep your personal data?
If you are successful in your application your data will be kept on your personnel/employee file. We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so. When we have no ongoing legitimate business need to process your personal data, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your personal data and isolate it from any further processing until deletion is possible. Generally this means your personal information will be kept for the duration of the application process plus a reasonable period of time after confirmation that your application was unsuccessful. We will delete this information from the servers at an earlier date if you so request, as described below.
Transfers of personal data outside the EEA
We are headquartered in the United States. Therefore, we may transfer your personal data outside the EEA to members of our group and to sub-processors. You can review the list of sub-processor in Appendix C (below). Where necessary these transfers are covered by an intra-group transfer agreement ensuring appropriate and suitable safeguards with our group members. If you wish to see details of these safeguards, please contact Aelieve by emailing [email protected].
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. Three of those grounds can be summarised as Legal Obligation, Legitimate Interests, and Consent. We outline what those terms mean below:
- Legal obligation
- Ground for processing: Processing necessary to comply with our legal obligations
- Explanation: Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination, or complying with immigration laws and regulations.
- Legitimate interests
- Ground for processing: Processing necessary for our or a third party’s legitimate interests.
- Explanation: We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data. Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
- Grounds for processing: Processing based on your consent.
Processing sensitive personal data
If we process sensitive personal data about you, 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 explained below. This is not an exhaustive list of examples.
- Recruitment for jobs at Aelieve
- Examples of personal data that may be processed: Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or, insofar as required or permitted by local law, background checks and any information connected with your right to work. If relevant, and insofar as permitted or required by local 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 interests
- Contacting you or others on your behalf
- Examples of personal data that may be processed: Your address, email address, and phone number.
- Grounds for processing: Legitimate interests
- Monitoring of diversity and equal opportunities
- Examples of personal data that may be processed: Insofar as permitted and/or required by local law information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age.
- Grounds for processing: Legitimate interests
- Submitting your information to process visa applications
- Examples of personal data that may be processed: Insofar as permitted and/or required by local law information, your National identifiers such as nationality/ies, national IDs/passport, social security/insurance numbers, immigration information, and visa status;
- Grounds for processing: Legal obligation or performance of a contract.
Who gets to see your data?
Your personal data may be disclosed to managers, HR and administrators for employment, administrative and management purposes as mentioned in this document. We may also share your data with external law firms for assessment of employment matters, permits, and visa options. We may also disclose this to other members of our group.
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 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.
- To exercise any of these data subject rights, please contact us by emailing [email protected].
You have the right to complain to a data protection authority about our collection and use of your personal information.
You may also raise complaints with the statutory regulator in your jurisdiction.
Please see the Appendix relevant to the jurisdiction in which you applied for a position for information about the relevant statutory regulator.
In processing your data we, and in some cases our group companies, may act as a data controller. Please contact us by emailing [email protected].