As part of any recruitment process, Winshuttle (“the organization”) collects, stores and processes personal data relating to job applicants. The organization is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the organization collect?
The organization collects a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- rights to work information e.g. copies of passports, ID cards, residence permits; and
- assessment results e.g. psychometric assessment results.
The organization may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
The organization may also collect personal data about you from third parties, such as references supplied by former employers. The organization will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does the organization process personal data?
In order to manage your application, we need to process certain personal information about you. We only process your information as necessary for the purposes of progressing your application or as required by law.
The organization needs to process data to take steps at your request prior to entering into a contract with you. It will also need to process your data to enter into a contract with you.
In some cases, the organization needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the country where the job is, before employment starts.
The organization has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organization to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organization may also need to process data from job applicants to respond to and defend against legal claims.
If your application is unsuccessful, the organization may keep your personal data on file in case there are future employment opportunities for which you may be suited. The organization will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the global organization. Individuals performing administrative functions and IT personnel within the organization may also have a limited access to your personal data in order to perform their jobs.
The organization will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organization will then share your data with former employers to obtain references for you.
As a global organization, your data may be transferred outside the European Economic Area (EEA) to the US and other countries where the organization has operations. We comply with EU-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from the European Union member countries. In addition, the organization has entered into Data Transfer Agreements with its operations globally governing its treatment of personal information of European Union residents.
How does the organization protect data?
Our HR and Recruitment systems are protected to ensure that unauthorised or unlawful processing of personal information, accidental loss or destruction of, or damage to, personal information does not occur. This is done in accordance with the organization’s Security Policy.
Where information is shared with other parties located outside your country, as a minimum, the organization will require that such personal information is protected as required by the laws of the country where you work. The organization also requires its third-party suppliers or recipients of personal information to guarantee the same level of protection as provided by the organization.
For how long does the organization keep data?
If you accept an offer of employment by us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements. If we do not employ you, the organization will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow the organization to keep your personal data on file, the organizations will hold your data on file for a further 6 months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the organization to change incorrect or incomplete data;
- require the organization to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
- object to the processing of your data where the organization is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact DPO@winshuttle.com in the first instance.
If you believe that the organization has not complied with your data protection rights, you can complain to the Information Commissioner. For further information on your rights and how to complain to the ICO, please refer to the ICO website.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organization during the recruitment process. However, if you do not provide the information, the organization may not be able to process your application properly or at all.