Praesidiad is the group company of certain businesses, including Hesco, Betafence and Guardiar
Praesidiad Applicants’ Data Protection Policy
Latest update: 25 May 2018
This data protection policy (hereinafter: “Applicants’ Data Protection Policy”) governs the processing of your personal data by Praesidiad Group Limited (hereinafter: “Praesidiad”) and its affiliates (including Hesco, Betafence and Guardiar) as part of your application for a job at Praesidiad or any of its affiliates, either through the use of the Praesidiad website or any other website of any of Praesidiad’s affiliates (the “Websites”) or by any other means, and subsequent communication with us including via e-mail, telephone, fax and Social Media Channels (e.g. LinkedIn) in relation to any job offers.
NOTE 1. This Applicants’ Data Protection Policy relates to the specific processing of personal data of applicants applying for a job at Praesidiad or its affiliates. For our general policy in relation to the use of our Websites and our communication with you in any other capacity than as a job applicant, please refer to our General Data Protection Policy.
NOTE 2. If you want information on how we process personal data via cookies, social plugins and other types of tracking technology, please refer to our Cookie Policy.
By submitting an application via any of the Websites, a third party recruiter, a third party website, directly to us, or by any other means, you acknowledge that you have read this policy carefully and that you agree with it without reservation.
1. IN GENERAL
1.1 Your personal data are processed by Praesidiad Group Limited, York House 221 Pentonville Road London N1 9UZ, with corporate registration number 10847053, and its affiliates (hereinafter: “Praesidiad”, “we”, “us”, “our”). You can contact us via e-mail at gdpr@praesidiad.com
1.2 Any notion starting with a capital shall be defined by explicit reference in this Applicants’ Data Protection Policy. Where possible, given the context, singular words shall be interpreted as also including the plural and vice versa.
1.3 Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.
1.4 We reserve the right to modify, change or amend the Applicants’ Data Protection Policy at our own discretion and from time to time. Such modification, change or amendment shall be communicated via the Praesidiad website. If you do not accept the modifications, changes or amendments, you can inform us by sending an e-mail to gdpr@praesidiad.com.
2. TYPES OF PERSONAL DATA WE PROCESS
2.1 Whenever you apply for a job with us, through the use of the Websites or in any other manner, we may collect the following personal data about you:
• Your contact details and basic identity information, such as your name, e-mail address, phone number and postal address;
• Your resume and resume-related information, such as former and current employer, work experience, education, skills, references, current grade and salary, etc.;
• Personal data pertaining to your nationality and your social security identity;
• Any personal information we obtain from you or third parties as part of a reference checking process;
• Any personal information you choose to upload as part of a document supporting your application.
2.2 In principle we obtain the above mentioned personal data directly from you. However, if you choose to apply via an external recruitment agency, your personal data are received by us via the external recruitment agency. It is the agency’s responsibility to relay the information contained in this Applicants’ Data Protection Policy to you. We advise that you consult the data protection policy of your external recruitment agency to ascertain what data they process about you, what the conditions for that processing are and how you can exercise your rights vis-à-vis the external recruitment agency. We will not send any of the personal data you provide via the Websites or in any other manner to external recruitment agencies unless you explicitly consent to it.
2.3 Should you be offered a position, our internal recruitment department may also add personal data pertaining to your application to your profile.
2.4 Our application process, in particular through an application form on any of the Websites, is not meant to involve the processing of personal data that can be construed as sensitive data. Sensitive data are personal data that pertain to your race or ethnicity, political affiliations, religious convictions, membership of a union, your health or sex life or criminal history. If such information becomes relevant as part of the application process, you will be specifically asked for it and be given the opportunity to consent to the processing of these sensitive data separately.
If you nevertheless choose to upload or otherwise provide sensitive data about yourself, your uploading or provision of these shall indicate your freely given, specific, informed, explicit and unambiguous written consent to the processing of these data in line with this Applicants’ Data Protection Policy.
3. PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
3.1 We process your personal data to allow you to apply for interesting positions with us.
3.2 We may also process your personal data in order for you to receive relevant and personalized information regarding future opportunities for employment with us.
3.3 If an application process for a particular position with us leads to a successful outcome, the personal data you provided may be used for human resources purposes during your employment with us.
3.4 We may process your personal data to perform statistical analysis to improve our application and recruitment services and our service offering in general. Such processing shall take place in a pseudonymized manner where possible.
3.5 We process your personal data to comply with our legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
3.6 We may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU.
3.7 We may process your personal data for the preservation of our legitimate interests or those of our partners or a third party, in particular if and when your use of the Websites or your application in general can be considered: (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Websites, (c) a danger to our other Websites, Social Media Channels or other communication channels or any of our or our subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminatory, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
4.1 For processing your personal data for the purposes outlined in Clauses 3.1 and 3.2 of this Applicants’ Data Protection Policy, we as the responsible party ask for your consent.
4.2 The processing of your personal data for the purpose outlined in Clause 3.3 of this Applicants’ Data Protection Policy is necessary for the protection of our legitimate interests, including to save time and resources in order to run a more efficient business by re-using already available information where permitted.
4.3 The processing of your personal data for the purpose outlined in Clause 3.4 of this Applicants’ Data Protection Policy is necessary for the protection of our legitimate interests, including to continuously improve our Websites, Social Media Channels, products and services to ensure that you have the best experience possible.
4.4 The processing of your personal data for the purpose outlined in Clause 3.5 of this Applicants’ Data Protection Policy is necessary to allow us to comply with our legal obligations.
4.5 The processing of your personal data for the purpose outlined in Clause 3.6 of this Applicants’ Data Protection Policy is necessary for the protection of our legitimate interests, including to merge and demerge, and to acquire and be acquired by third parties.
4.6 The processing of your personal data for the purpose outlined in Clause 3.7 of this Applicants’ Data Protection Policy is necessary for the protection of our legitimate interests, including to keep our Websites, Social Media Channels, products and services safe from misuse and illegal activity.
5. TO WHOM WE SEND YOUR DATA
5.1 We rely on third party processors to provide you our Websites and Social Media Channels, as well as to process your personal data on our behalf. These third party processors are only allowed to process your personal data on our behalf upon our explicit written instruction.
5.2 We may share your personal data with other entities within our Group. However, we will take appropriate measures to ensure that all entities within our Group take due care that all processing of your personal data is in line with what is set out in this Applicants’ Data Protection Policy.
5.3 Your personal data may be shared upon our own initiative with the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you in the context of your application.
6. LOCATION AND TRANSFER
6.1 We process your personal data first and foremost within the European Economic Area (EEA). However, in order to process your personal data for the purposes outlined in Clause 3 of this Applicants’ Data Protection Policy, we may also transfer your personal data to other entities within our Group or to third parties who process on our behalf outside the EEA. Should such transfer take place, Praesidiad will ensure that there are safeguards in place to ensure the safety and integrity of your data as well as all rights with respect to your personal data you might enjoy under applicable mandatory law.
6.2 Each entity outside the EEA that processes your personal data shall be bound to observe adequate safeguards in order to ensure the safety and integrity of your data. Such safeguards will be the consequence of:
• The country of the recipient having legislation in place which may be considered equivalent to the protection offered within the EEA; or
• Of a contractual arrangement between us and that entity. All our entities are parties to a contractual agreement based on the European Commission’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721).
7. QUALITY ASSURANCES
7.1 Your personal data are only processed for as long as needed to achieve the purposes listed under Clause 3 of this Applicants’ Data Protection Policy or, regarding the purposes in Clause 3.1 and 3.2, up until such time where you withdraw your consent for processing them. We will de-identify your personal data when they are no longer necessary for the purposes outlined in Clause 3 of this Applicants’ Data Protection Policy, unless there is:
• An overriding interest of Praesidiad, your financial institution, the payment service provider, or any other third party, in keeping our personal data identifiable;
• A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
7.2 You understand that an essential aspect of the use of our Websites, or otherwise applying for a role with us or our affiliates, involves assessments of your professional as well as relevant personal characteristics in order to find you a suitable position with us or our affiliates, or to determine your suitability for a given position. This means that we build and use a profile of you based on these relevant characteristics. Note, however, that these assessments are never fully automated and require human intervention.
7.3 We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by our personnel or our third party processors will only be on a need-to-know basis and will be subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.
8. YOUR RIGHTS
8.1 You have the right to request access to all personal data relating to you that is processed by us. However, we reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for the purpose of causing us nuisance or harm.
8.2 You have the right to ask that any personal data relating to you that are inaccurate are corrected free of charge. If you submit a request for correction, such request must be accompanied by proof of the accuracy of the correction you are seeking.
8.3 You have the right to withdraw your earlier given consent for the processing of your personal data.
8.4 You have the right to request that personal data relating to you be deleted if they are no longer required in the light of the purposes outlined in Clause 3 of this Applicants’ Data Protection Policy or, regarding the purposes in Clause 3.1 and 3.2, when you withdraw your consent for processing them. However, you should keep in mind that a request for deletion will be evaluated against:
• Our overriding interests or those of any other third party;
• Any legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that we limit the processing of your personal data if and when: (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data are no longer needed for the purposes listed under Clause 3.
8.5 You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with the particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
8.6 You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
8.7 If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to gdpr@praesidiad.com. An e-mail requesting to exercise a right shall not be construed as consent to the processing of your personal data beyond what is required for handling your request. Any request should be dated and clearly state which right you wish to exercise and the reasons for it if such is required. The circumstances may mean we need to undertake verification of your identity before we action your request in order to protect your personal data to the relevant standard.
We will promptly inform you of having received this request. If the request proves valid, we will action it as soon as reasonably possible and at the latest thirty (30) days after having received the request.
If you have any complaint regarding the processing of your personal data by us, you may always contact us via the e-mail address listed above. If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority.