Data protection privacy notice for recruitment

This notice explains what personal data (information) we will hold about you from which you can be identified, how we collect it, and how we will use and may share information about you during the application process. This does not include data where your identity has been removed (anonymous data) but may include “special categories” of more sensitive personal data which require a higher level of protection. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who collects the information

Vaimo is a group companies, namely those listed in Schedule 1 to this notice (the ‘group companies’) singularly or together referred to as ‘Vaimo’ and, in this notice, references to ‘we’ or ‘us’ mean Vaimo. Vaimo is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies.

About the information we collect and hold

What information we collect

We may collect the following information up to and including the shortlisting stage of the recruitment process:

• Your name and contact details (i.e. address, home and mobile phone numbers, email address);
• Details of your qualifications, experience, employment history (including job titles and working hours) and interests set out in your CV or other documentation provided during the recruitment process;
• Results of tests completed during the recruitment process; and
• Details of your referees.

We may collect the following information after the shortlisting stage, and before making a final decision to recruit:

• Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
• Information regarding your academic and professional qualifications; and
• Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information.

We may also collect, store and use the following “special categories” of more sensitive information:

• Your racial or ethnic origin, or your sex; and
• Information regarding your criminal record, if considered necessary by Vaimo, but you will always be notified in advance of any such activities.

As we need to have further justification for collecting, storing and using this type of sensitive information. We will, if necessary, process special categories of information in the following circumstances:

• Where we need to carry out our legal obligations and in line with our data protection policy;
• Where it is in line with our data protection policy, it is substantially in the public interest to do so and necessary for:
  • equal opportunities monitoring; or
  • preventing or detecting unlawful acts

In accordance with our obligations as an employer, we will use your sensitive information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

We do not need your consent if we use special categories of your information in accordance with our written policy to carry out our legal obligations, or for one of the other reasons outlined below in the section: “Why we collect the information and how we use it”.

In limited circumstances, if the need arises, we will approach you for your written consent to allow us to process certain sensitive information. If we do so, we will provide you with full details of the information that we would like to process and the reason why, so that you can carefully consider whether you wish to consent. You should be aware that you are not obliged to agree to any request for consent from us.

How we collect the information

We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body and any government authority.

Why we collect the information and how we use it

We will only use your personal information when the law allows us to.

We will typically collect and use this information for the following purposes (other purposes that may also apply are explained in our Employee data protection privacy notice):

• to verify your right to work and suitability for the position and, if your application is successful, creating your personnel record;
• for compliance with our legal obligations (e.g. our obligation to check that you are eligible to work in the country where the respective Vaimo group company is incorporated in);
• for the performance of a task carried out in the public interest, such equal opportunities monitoring.; and
• for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms, such as:
  • contacting you in connection with your application;
  • analytics and profiling for statistical analysis and to help us understand more about the people who apply for jobs with us and validating the fairness of our tests;
  • contact your referees to obtain references;
  • carrying out pre-employment checks, for certain roles, although typically we do not conduct these unless you have been offered a role.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

How we may share the information

We may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations and are required to take appropriate security measures to protect your information in line with our policies. We do not allow our third-party service providers to use your information for their own purposes and only permit them to process your information for specified purposes and in accordance with our instructions. We may also be required to share some personal information with our regulators or as required to comply with the law.

Transferring information outside the European Economic Area (EEA)

If we need to transfer your information we collect about you outside the EEA, to ensure that your information receives an adequate level of protection, we will only make transfers: (i) to a country which the European Commission has made a positive finding of adequacy for, or (ii) under the standard clauses approved by the European Commission.

Failure to provide information

If you fail to provide certain information when requested, we may not be able to consider application further or continue with the recruitment process, or we may be prevented from complying with our legal obligations.

Where information may be held

Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents.

How long we keep your information

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.

We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.

If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see Employee data protection privacy notice.

Your rights

Under certain circumstances, you have the right to:

• Request access to your information. This enables you to receive a copy of the information we hold about you and to check that we are collecting and using it lawfully.
• Request correction of the 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 information. This enables you to ask us to delete or remove some but not all of the information we hold and process (the ‘right to be forgotten’) where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your information where you have exercised your right to object to processing (see below).
• Object to processing of your information. This applies 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 collecting and using your information. This enables you to ask us to suspend the usage of information about you, e.g. if you want us to establish its accuracy or the reason for processing it.
• Request the data portability of your information to another party.
• Lodge a complaint to supervisory authority.
• Withdraw consent. In circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

Please contact our legal department, via email [email protected] if (in accordance with applicable law) you would like to access, review, verify, correct or request erasure of your information, object to the processing of your information, request that we transfer your information to another party or withdraw the consent or if you have any questions about this notice.

In order to meet your request we may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

Exercising your rights is free from charges. However, we have right at our sole discretion to refuse to fulfil or charge a reasonable fee for fulfilling of several similar consecutive requests or requests that are manifestly unfounded or excessive. We are also entitled to decline requests on statutory grounds in which cases we will inform you of the reasons for this.

To lodge the complaint with the supervisory authorities, please contact the supervisory authority in your country directly or Vaimo’s lead authority in Sweden (Sw. Datainspektionen, www.datainspektionen.se).

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Informing us of changes to your information

It is important that the information we hold about you is accurate and up to date. Please keep us informed if your personal information changes.

How to complain

You can raise any query or concern about our use of your information with our legal department via [email protected]. If we are not able to resolve your query or concern, please contact supervisory authority in your country of residence, country of work, country of alleged infringement or Vaimo’s lead authority in Sweden (Sw.Datainspektionen, www.datainspektionen.se) for further information about your rights and how to make a formal complaint.

Schedule 1 to the Data protection privacy notice for recruitment

List of Vaimo group companies

VAIMO AB

VAIMO SWEDEN AB

VAIMO GROUP SERVICES AB

VAIMO OÜ

VAIMO UK LIMITED

VAIMO INTERNATIONAL LIMITED

VAIMO SA (PTY) LTD

”VAIMO UKRAINE” LTD.

VAIMO A/S

VAIMO NORGE AS

VAIMO FINLAND OY

VAIMO DMCC

VAIMO ECOMMERCE SERVICES (PTY) LTD

VAIMO BENELUX NV

VAIMO JAPAN INC.

VAIMO PHILIPPINES

VAIMO PIM AB

VAIMO POLAND sp. z o.o

VAIMO FZ LLC

VAIMO BENELUX BV

VAIMO Inc.