PRIVACY NOTICE FOR APPLICANTS / CANDIDATES
SSI EUROPE UK LIMITED/SERVICESOURCE INTERNATIONAL BULGARIA EOOD/SERVICESOURCE EUROPE LIMITED
Last Updated: November 11, 2019
1. What is the purpose of this document?
As applicable, SSI EUROPE UK LIMITED/SERVICESOURCE INTERNATIONAL BULGARIA EOOD/SERVICESOURCE EUROPE LIMITED (“we” or the “Company“) is a “data controller”. This means that the Company is responsible for deciding how we hold and use personal data about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR). This Privacy Notice applies only to candidates in the EU applying for positions with SSI Europe UK Limited, ServiceSource International Bulgaria EOOD or ServiceSource Europe Limited.
2. 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; and
- kept securely.
3. The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you:
- the information you have provided to us in your CV and covering letter;
- the information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications;
- any information you provide to us during an interview;
- language assessments (written and/or verbal);
- If you are in Bulgaria, we will also collect information about your historic residential addresses.
4. How is your personal data collected?
We collect personal data about candidates from the following sources:
- you, the candidate;
- The agencies set forth on Schedule 1 from which we collect the following categories of data: CV and covering letter, information on any application form, confirmation of language skills, assessments (i.e. written or verbal assessments). Please note that these agencies may also assist with our background checks which includes obtaining references;
- the following data from third parties is from a publicly accessible source: LinkedIn
- your named referees, from whom we obtain a standard reference (often via a recruitment agency); and
- job boards, such as Reed or CV-Library.
5. How we will use information about you
We will use the personal data we collect about you to:
- assess your skills, qualifications, and suitability for the role;
- carry out background and reference checks, where applicable;
- communicate with you about the recruitment process;
- keep records related to our hiring processes; and
- comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you to a role, as it is beneficial to our business to recruit when the need arises.
We also need to process your personal data to decide whether to enter into a contract of employment or engagement with you.
Having received your CV and covering letter or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.</p
6. If you fail to provide personal data
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
7. How we use particularly sensitive personal data
We will use your particularly sensitive personal data in the following ways:
- We will use information 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 an interview.
- We will use 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.
8. Information about criminal convictions
Except as set forth below, we do not envisage that we will process information about criminal convictions. If that should change based on the role you are applying for, we will let you know.
Certain highly regulated clients require a basic criminal record check performed by the Disclosure & Barring Service (the DBS) for any individual working on their accounts.
In order to preserve the safety and security of our customers’ data, if you will be working on such an account, we will ask you to permit us to carry out a basic DBS check, before your employment with us commences, but after an offer of employment has been made. The check will verify details of all unspent criminal convictions, conditional and unconditional cautions, or otherwise state that the individual concerned has no such convictions or cautions. This information is considered sensitive personal data for the purposes of the applicable data protection legislation and the Company may take this information into account when determining your suitability for employment and for placement on certain accounts.
In the event we do process information about criminal convictions as a result of the above the DBS check will be conducted by a third party provider.
9. Information about fraudulent activity.
Certain highly regulated clients require a review of the Cifas databases. Cifas databases have been established for the purpose of allowing organisations to record and share data on their fraud cases, other unlawful or dishonest conduct, malpractice and other serious improper conduct (“Relevant Conduct”) carried out by an organization’s staff and potential staff. “Staff” means an individual engaged as an employee, director, trainee, homeworker, consultant, contractor, temporary or agency worker or self-employed individual, whether full or part time or for a fixed term.
In the event we do process information about Relevant Conduct as a result of the above the Cifas check may be conducted by a third party provider. Further, in such event, the personal information we have collected from you in connection with the application process will be shared with Cifas who will use it to prevent fraud, other unlawful or dishonest conduct, malpractice and other seriously improper conduct If any of these are detected, you could be refused certain services or employment. Your personal information will also be used to verify your identity. Further details of how your information will be used by us and Cifas, and your data protection rights, can be found at https://www.cifas.org.uk/fpn.
10. Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
11. Recipients of your personal data</h >
We may disclose your personal data to members of our HR team, the relevant team managers and colleagues in respect of the role you are applying for in order to take hiring decisions.
It may be necessary from time to time for us to disclose your personal data to third parties or agents, including without limitation to the following:
- third parties or agents of clients to assist in the administration, processing and management of certain activities pertaining to prospective employees including external reference agencies (such as employee vetting and screening agencies) and travel and expense management service providers;
- individuals or companies employed by the Company to carry out specific services, functions or consultancy work and other financial institutions;
- relatives or legal representatives of prospective employees;
- regulatory bodies to whom we are obliged or required to disclose information including Workplace Relations Commission, Courts and Court-appointed persons;
- relevant Government departments and agencies;
- other support service providers necessary to support the organisation in the services listed; and.
- as noted in Section 9 above, Cifas.
Why might you share my personal data with third parties?
Except as set forth in Section 9 above, we will only share your personal data with the following third parties for the purposes of processing your application:
- ServiceSource International, Inc.
- ServiceSource International Philippines, Inc.
- ServiceSource International International Malaysia SDN
- ServiceSource International Japan G.K.
- ServiceSource International Singapore Pte., Ltd.
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. Except as noted in Section 9 above, 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.
12. Transfer of personal data outside the EEA
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), for the purposes described above. Those countries may not provide an adequate level of protection in relation to processing your personal data. Due to the global nature of our business, your personal data may be disclosed to members of our group outside the EEA, including in particular in the USA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers who act on our behalf. We will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data. You can obtain information concerning such safeguards from via firstname.lastname@example.org, where applicable.
13. 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 email@example.com.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
14. How long will you use my information for?
We will retain your personal data for a period of 6 to 12 months (6 months in the UK and Bulgaria and 12 months in Ireland) after we have communicated to you our decision about whether to appoint you to the role. 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.
It is likely that we will wish to retain your personal data on file for up to 18 months, on the basis that a further opportunity may arise in future and we may wish to consider you for that. If so, we will write to you separately, seeking your explicit consent to retain your personal data for a fixed period on that basis.
15. 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 information 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
- 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 want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact firstname.lastname@example.org.
16. Right to withdraw consent
If you have provided consent to us processing your personal data for the purposes of the recruitment exercise, you have the right to withdraw such consent at any time. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
17. Candidate Responsibilities
You should use all reasonable endeavours to keep us informed of any changes to your personal and special personal data. If you become aware of a data breach or a potential data breach in respect of personal data please report the matter immediately to the Legal Department by email at the following address firstname.lastname@example.org.
18. Data Protection Manager
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the [data privacy manager by email at this address email@example.com.
You have the right to lodge a complaint with the applicable supervisory authority, the details of which can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en#dataprotectionauthorities
20. Further Information
If you require any further clarification regarding this privacy notice, please contact the Company via firstname.lastname@example.org.
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