ITRANSITION RECRUITMENT PRIVACY STATEMENT
This statement applies for all job candidates (“you”) who come into contact with us via this website or other career resources, including recruitment agencies.
It explains what information about you Itransition sp. z o.o., together with its affiliated companies (collectively hereinafter referred to as “Itransition” or “we”), collects, what for it does it and how the information is used/processed by it during the recruiting and any hiring process or after it. The statement additionally serves to provide you with information on the rights to which you are entitled in regard to the processing of your personal data by Itransition.
We are a group of companies that act as joint controllers of your personal data. It means that the companies of the group jointly determine the purposes and means of personal data processing.
The controllers are:
Itransition sp. z o.o. Grzybowska str. 43, of.120-121, 00-855 Warsaw, Poland
Itransition Group Limited 3rd floor, 5-8 Dysart Street, London EC2A 2BX, United Kingdom
Itransition CJSC Kulman st. 1, 220013 Minsk, Belarus
Personal information we collect and use
We do not collect more information than we need to fulfil our purposes listed in this statement and will not keep it longer than necessary.
The types of information requested from you and the manner in which that information is collected and accessed are determined by the requirements of the country in which the position is located, and not the country in which you reside. You are not required to provide any requested information to us, but failing to do so may result into not being able to continue your candidacy for the job for which you have applied. By submitting your information, you acknowledge that all representations made by you are true and correct to the best of your knowledge and belief. Providing any inaccurate information may make you ineligible for employment.
Types of information about the candidate that normally reside in our files are as follows: contact details (e-mail address and phone number), social and professional profiles, education and work experience. In connection with your job interviews, we receive additional information about you which we record for use in the further recruitment process.
Your files can also include letters or other written materials, data generated by interviewers and recruiters, based on their interactions with you or basic Internet searches as well as their considerations regarding you and your suitability to the role, recommendations provided on your behalf by others, documentation required under immigration laws, data generated by your participation in technical assessments.
Purposes for which we collect and use your personal data
The permissibility of personal data processing can only be established when the processing of the data can be supported by an appropriate legal basis. During the recruitment and hiring process, we will use your personal data for the following purposes and on the following legal bases:
|1||to manage your application||in order to take steps at your request prior to entering into a contract|
|2||to facilitate communication with you|
|3||in some cases, to record your online interview for review by additional recruiters and your potential future managers|
|4||to assess your suitability for the role for which you have applied for and make decision on your possible employment|
|5||to negotiate and agree with you terms on which you work for us in case your application was successful|
|6||to consider you and contact you about roles potentially suitable for you in future||on the basis of your consent to become a member of our talent database and to receive information about new positions which we think might be of interest to you|
We may also need to process your personal data to respond to and defend against legal claims. In some cases, we need to process your data to ensure that we are complying with our legal obligations. For example, we are required to check a successful candidate’s eligibility to work in the United Kingdom before employment starts.
We may process information about whether or not you are disabled so we can make reasonable adjustments for a candidate with a disability. This is to carry out our obligations and exercise specific rights in relation to employment.
We will not use your personal data for purposes that are incompatible with the purposes listed in this statement, unless it is required or authorized by law, or it is in your own vital interest to do so.
Sources from which we obtain your personal data
We may obtain data about you from the following sources:
- from you when you submit your CV or other information online and get interviewed by us for the role you have applied for,
- from other companies of Itransition,
- from Itransition employees and contractors whom you gave your consent to share your application with us,
- from your previous employers,
- from social media,
- from third-party recruiters whom you gave your consent to provide us with your application information.
Cookies are small text files that may be placed and stored on your computer/device allowing internet access when you visit this website.
Cookies are placed on your computer/device only if you consent to it, unless cookies are necessary for strictly technical functionality of the website.
You can opt-out from analytics by disabling cookies through your browser settings or by visiting https://tools.google.com/dlpage/gaoptout/.
If you want to disable other cookies, you can learn how to do it by visiting http://www.allaboutcookies.org.
Automated decision-making including profiling
Unless otherwise explicitly described in this statement, no automated decision-making takes place.
Who may access your personal data
We may disclose your personal data to (1) our employees who are in contact with you or who are responsible for or are involved in recruitment and hiring process, including your potential future managers and their designees, personnel in HR, IT, compliance and legal departments, (2) other companies of Itransition (some of them are located outside the European Union), (3) third-party service providers.
Statistical data about this website’s visitors may be accessed by (1) our employees in HR, marketing and/or IT departments who are responsible for analysing such data and for improving our websites, (2) other companies of Itransition (some of them are located outside the European Union), (3) third-party service providers.
Transfer to third countries
We are a multinational group of companies. For this reason, for reasons of administration of the recruitment and hiring process and for purposes described in section “Purposes for which we collect and use your personal data” of this statement, your personal data may be transferred to, processed and stored outside the country where you are located. This includes countries outside the European Economic Area with no adequate level of personal data protection (third countries).
As some of the countries where our offices are situated are not yet recognized by the European Commission as countries with an adequate level of personal data protection, these offices have access to personal data on the basis of instruments that cover the European Union requirements for the transfer of personal data to data controllers/processors outside the European Union. You can inspect copies of these documents by contacting our Data Protection Officer at firstname.lastname@example.org.
When we transfer personal data, we do so for the purposes for which the information has been collected/submitted, for the purposes listed above, for the administration and maintenance of its websites and associated systems, and/or other internal or administrative purposes. We also may transfer personal data to third parties providing identity management, website hosting and management, data analysis, data backup, security and storage services.
Where you are represented by a recruitment agency which is involved in your recruitment and hiring process with us, we will share information about your interview(s), offer(s) with them so they can discuss it with you.
We work only with those third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal data only as instructed by us and to flow those same obligations down to their sub-processors.
We take appropriate technical and organizational security measures and have rules and procedures in place to make sure your personal data is kept securely and to guard against unauthorized access, improper use, alteration, disclosure and destruction and accidental loss of your personal data.
In addition, we limit access to your personal data to only authorized staff and to those who have business need to know (and they will only process your personal data on our instructions and subject to a duty of confidentiality).
We have put in place procedures to deal with any suspected or actual data security breach and will notify you and to the supervisory authority of a suspected breach where we are legally required to do so.
Whenever we propose using new technologies, or where processing is construed as high risk, we are obliged to carry out a data protection impact assessment which allow us to make sure appropriate security measures are always in place in relation to the processing of your personal data.
Retention of your personal data
We will keep your personal information as long as you are a candidate. After you stop being a candidate, we may keep your data for a reasonable period of time to deal with any matter which may arise in connection with your application, e.g. to respond to any questions or complaints, to resolve possible disputes/claims or to show that we treated you fairly, or to make sure we do not contact you about a role you have already applied for.
If you consent to joining our talent pool, we may also retain your personal information for up to 2 years (after we have communicated to you our decision about your application being unsuccessful) for purposes of assessing your suitability for other roles and contacting you regarding other employment opportunities. You can withdraw your consent regarding such processing of your personal data at any time.
If your application for employment is successful, your personal data gathered during the recruitment and hiring process will be transferred to your personnel file and retained during your employment.
We may keep your data for longer than 2 years if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected.
Rights you have in relation to your personal data
Under your local laws and the European Union legislation, you may exercise the following rights by submitting your request/inquiry to us:
- right to require access to your personal data – this right entitles you to request access to personal data we process about you, as well as to certain information on such processing;
- right to require rectification of your personal data – this right entitles you to request the change of any of your personal data which is inaccurate or incomplete;
- right to require erasure of your personal data – this right entitles you to request the erasure of your personal data, including where we no longer need your personal data for the purposes for which it was collected or otherwise processed. Provided that we do not have any continuing lawful reasons to continue processing your personal data, we will make reasonable efforts to comply with your request;
- right to request the restriction of the processing of your personal data – this right entitles you to request that we only process your personal data in limited circumstances, including with your consent;
- right to object to the processing of your personal data – this right entitles you to request that we no longer process your personal data;
- right to data portability – this right entitles you to receive a copy of your personal data which you have provided to us in structured, common and machine-readable format insofar as it has not already been deleted;
- right to withdraw your consent regarding processing of your personal data – you can apply this right only if the processing of your personal data is based on your consent. Please note that this will not affect the lawfulness of processing based on consent before your withdrawal of consent, nor our right to continue parts of the processing based on other legal bases than your consent;
- right to lodge a complaint with your supervisory authority – you can use this right if, despite our commitment and efforts to protect your personal data, you believe your data protection rights have been infringed. The complaint can be lodged in the Member State where you live, work or where you assume the alleged violation took place.
If you have any questions, comments, requests or complaints regarding this Recruitment Privacy Statement or the processing of your personal data by us, you can contact our Data Protection Officer at email@example.com. You can also reach us via the contact information given in this Statement above.
This statement may change. We will not reduce your rights under it without your consent. If any significant change is made to this statement, we will provide a prominent notice on this website so that you can review the updated statement.
In the event of any conflict between the English version and any translation of this statement, the English version of this statement shall prevail.
Last update: July 2019