GDPR CANDIDATE PRIVACY NOTICE

Date: 4 March 2023

CONTENT: 

  1. PURPOSE OF THIS NOTICE
  2. CONTROLLER
  3. DATA PROTECTION PRINCIPLES
  4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
  5. HOW IS YOUR PERSONAL DATA COLLECTED
  6. HOW WE WILL USE YOUR PERSONAL DATA
  7. FAILURE TO PROVIDE YOUR PERSONAL DATA
  8. HOW WE USE SENSITIVE PERSONAL DATA
  9. AUTOMATED DECISION MAKING
  10. DATA SHARING
  11. DATA SECURITY
  12. DATA RETENTION
  13. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
  14. RIGHT TO WITHDRAW CONSENT
  15. ADDRESS DATA PROTECTION QUERIES

1.PURPOSE OF THIS NOTICE

ASBISC ENTERPRISES PLC and its affiliates (“ASBISC”, “we”, “us”, “the Company”) respect your privacy and are committed to protecting your personal data. As part of our recruitment process, we collect and process personal data relating to candidates. We are committed to be transparent about how we collect and use your personal data and to meet our obligations under the General Data Protection Regulation (EU 2016/679), (the “GDPR”). This privacy notice contains information about how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will be retained for. It provides you with certain information that must be provided under the GDPR and the local data protection law (the “Privacy Notice”).

2.CONTROLLER

ASBISC is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you.

3.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.
  • Kept securely.

4.THE KIND OF INFORMATION WE HOLD ABOUT YOU

In connection with your application for work, we will collect, store, and process the following categories of personal data about you:

  • The information you have provided to us in your CV and covering letter (if applicable).
  • The personal data entered by you in SHL online system for psychometric assessment, meaning your name, email, address, gender (optional), language, demographic information (optional), responses to assessments or surveys (if applicable).
  • The data you have provided through our application form, including name, last name, title, email address, phone number, location, Linkedin profile (If applicable).
  • Any information you provide to us during an interview. Including but not limited to title, date of birth, gender, employment history, qualifications, nationality.
  • Information about criminal convictions and offences, information about health, including any medical condition, health and sickness records.
  • Any personal data provided to us by your referees (if applicable).

5.HOW IS YOUR PERSONAL DATA COLLECTED? 

We collect information about candidates from the sources indicated below:

  • You, the candidate
  • Our authorized third-party recruitment agencies, from which we collect information about you, including, name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications
  • Your named referees, from whom we collect the following categories of data: full name, periods of previous employment, performance during previous employment.
  • From publicly accessible sources such as Linkedin, Facebook etc., where we collect your full name, email, work history, and any other information available in your profile.

6.HOW WE WILL USE YOUR PERSONAL DATA

We will use the information we collect about you for the following purposes:

  • Communicate with you about the recruitment process.
  • Carry out background and reference checks.
  • Assess your skills, qualifications, and suitability for the position.
  • Keep records related to our hiring process.
  • Comply with legal or regulatory requirements.

After receiving your CV and cover letter (if applicable), we will process that information to decide whether you meet the basic requirements to be shortlisted for the position. If you do, we shall decide whether to invite you for an interview. We may also conduct an online Psychometric assessment. If you are called for an interview, we will use the information you provide to us during the interview, to decide whether to offer the position to you. If we decide to offer you the position, we will take up references. We also carry out a criminal record check.

It is in our legitimate interest to decide whether to appoint you to a position since it would be beneficial to our business to appoint the appropriate candidate to that position.

We also need to process your personal information to decide whether to enter into a contract of employment or engagement with you.

7.FAILURE TO PROVIDE YOUR PERSONAL DATA

You are under no obligation to provide data to the Company during the recruitment process. However, if you do not provide the information, the Company may not be able to process your application properly or at all.

8.HOW WE USE SENSITIVE PERSONAL DATA  

We will use your sensitive personal data in the following ways and only when permitted by applicable laws:

We will use data 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 during a test or interview.

We will use data about your nationality or ethnicity, to assess whether a work permit and a visa will be necessary for the role.

We will collect information about your criminal convictions history if we would like to offer you a role which is conditional on criminal background checks in order to make sure that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular, for roles that require a high degree of trust and integrity we may ask you to seek a basic disclosure of your criminal records history.

9.AUTOMATED DECISION-MAKING 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. 

10.DATA SHARING 

We will only share your personal data with the following third parties for the purposes of processing your application: ASBISC affiliates and third – party service providers. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service 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.

11.DATA SECURITY 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our website privacy notice.

12.DATA RETENTION 

We will retain your personal data for a period of 3 years after your last application date. We retain your personal data 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 data in accordance with our data retention policy. 

13.RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION 

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below).

Object to processing of your personal data 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 data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal data to another party.

If you wish to exercise any of the rights set out above, please send an email to dpo@asbis.com, or call us at +357 25 857 097 / 25 857 098. We will aim to respond to you within 30 days from receipt of the request. We will need to verify your identity before we are able to disclose any personal information to you.

14.RIGHT TO WITHDRAW CONSENT

You have the right to withdraw the consent you gave us in relation to the processing of your personal data at any time. To withdraw your consent, please send an email to dpo@asbis.com, or call us at +357 25 857 097 / 25 857 098, expressing your desire for withdrawal of your consent. Once we have received notification that you wish to withdraw your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

15.ADDRESS DATA PROTECTION QUERIES

Our Data Protection Officer oversees compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact our Data Protection Officer at dpo@asbis.com. You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection of Cyprus, the Cyprus supervisory authority for data protection issues.