Job Applicant Privacy Notice
January 2023
As part of any recruitment process, IH International Advisors Ltd. (“IHIA”, “we”, “our” or “us”) collects, handles and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations. This notice applies to all applicants who apply for employment in our UK office only.
IHIA acts as the data “Controller” for the processing of your personal data. Personal data will be processed in compliance with The UK General Data Protection Regulation, the Data Protection Act 2018 and any other applicable laws or regulations which implement or supplement the foregoing) (collectively, the “applicable data protection laws”). “Personal data”, “processor”, and “controller” have the meanings given in the applicable data protection laws.
Any questions about the contents of this privacy notice or how personal data will be used, stored, or transferred, should be sent to the IHIA Personal Data Protection Champions (“PDPCs”), being namely the General Counsel and COO at Privacy@IHinternational.com.
What personal data do we collect?
IHIA may collect and process a range of personal data about you. This includes, but is not limited to:
- your name, address and contact details, including email address and telephone number;
- gender, nationality, citizenship, date of birth, details of dependents and family members (where applicable);
- education and employment information (e.g. remuneration, bonus, pension entitlements, insurance and other benefits information, employment dates such as dates of hiring/promotion/position change, performance evaluation, position information such as position title and reference number, attendance information including illness or leaves of absence, language skills, degree grade/title, certificates, licences, memberships of committees or other bodies);
- records of interviews (including attendance details at our office) or interview notes. For certain roles, we will obtain the results from assessments we have conducted with you or from assessment agencies that have conducted an assessment with you;
- any feedback or opinions you voluntarily provide to us during the recruitment process;
- national insurance number, social security number or local equivalent;
- evidence of your right to work in the place of your prospective employment; and
- any other personal data which you choose to disclose to us during the course of the application process.
In principle, we do not collect or use any special categories of personal data of applicants, such as health data or other sensitive types of data, unless you provide this to us voluntarily as part of your application documentation or during an interview.
IHIA 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. IHIA may also collect personal data indirectly from recruiters, external assessors, academic institutions, certification providers and industry bodies, from other administration, or from publicly available sources (including via social media, to the extent that you choose to make your profile publicly available).
IHIA may carry out background checks as part of the application process and may use a third party for the purpose. Those checks may include criminal record checks, credit reference checks and similar background verification activities.
We may also, with your permission, collect personal data from any person who you have nominated as an employment referee.
For further details about the purposes for processing your personal data and the corresponding lawful basis, please see below:
| Purpose: | Lawful Basis: |
|---|---|
| For handling emergencies and maintaining on site safety and security: (a) ·communicating with designated contacts in case of an emergency; (b) Processing as required to ensure the safety and protection of IHIA’s employees, facilities, resources, and communities including (without limitation) protecting occupational health and safety and authenticating worker status to authorize access to IHIA’s technology, resources and facilities; and (c) conducting security screenings, to the extent permitted by law. | Necessary for the protection of the vital interests of the applicant or of another individualNecessary for the purposes of a legitimate interest of IHIA or other third parties* |
| For legal and regulatory purposes: (a) complying with applicable laws and statutory requirements such as income tax, national insurance deductions, and employment and immigration laws; and (b) responding to and complying with requests and legal demands from regulators or other authorities. | Necessary for compliance with legal obligations to which IHIA is subject in particular in the area of labour and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws |
| Where we have your consent: In principle, we do not rely on your consent to process your personal data. We will only do so in very limited circumstances. If we do so, we will provide you with full details of the data that we would like and the reason we need it, so that you can carefully consider whether you wish to freely consent. Where we rely on consent as a lawful basis, you have the right to withdraw your consent for use of your personal data at any time using the contact details provided in the section below headed “Your Rights”. | Consent |
| *To pursue our legitimate interests of hiring qualified people, to find the right candidates for future vacancies and to secure, defend and develop our business. We only use this legal basis if your interests and fundamental rights do not override our legitimate interests. | Necessary for the purposes of a legitimate interest of IHIA or other third parties* |
Why does IHIA process personal data?
We need to process personal data to manage your application through the entire application process and to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you. In some cases, we need to process data to ensure that we are complying with our legal obligations.
IHIA 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 us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
How does IHIA protect personal data?
We take the security of your data seriously. We have implemented adequate technical and organisational measures to protect personal data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. All personnel accessing your personal data must comply with the internal rules and processes in relation to the processing of personal data to protect them and ensure their confidentiality. They are also required to follow all technical and organisational security measures put in place to protect the personal data.
Who has access to personal data and with whom are they shared?
We may transfer personal data internally at IHIA on a need-to-know basis and to other companies of the group to which we belong (the “Interogo Holding Group”). Such other companies of Interogo Holding Group will either act as another controller under this notice or will only process personal data on behalf and upon request of IHIA.
We may also transfer personal data to third parties outside Interogo Holding Group to complete the purposes listed in the table above, to the extent they need it to carry out the instructions we have given to them. Such third parties may include:
- third parties who process personal data, such as our (IT) systems providers, our payroll provider, transport companies or travel agency, cloud service providers, database providers, consultants and third parties who carry out pre-employment checks and tests on prospective Co-workers. Where relevant, these third parties have entered into an agreement with IHIA (or another Interogo Holding Group member) to keep personal data secure;
- successors in title of our business in case of a corporate transaction;
- any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request; and
- any central or local government department and other statutory or public bodies.
The Personal Data transferred within or outside Interogo Holding Group above, may also be processed in a country outside the United Kingdom, Switzerland and the European Economic Area (collectively, the “equivalent standard jurisdictions"). Countries other than the equivalent standard jurisdictions may not offer the same level of personal data protection as the equivalent standard jurisdictions.
If your personal data is transferred outside the equivalent standard jurisdictions, we will put suitable safeguards in place to ensure that such transfers is carried out in compliance with the applicable data protection laws. You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.
For how long does IHIA keep data?
We will keep your personal data for long as necessarily to fulfil the purpose for which it was collected.
If your application for employment is unsuccessful, we will keep your personal data on file for three months (from the date that we communicate this) in case of any potential legal claim.
We may ask your consent to contact you about future employment opportunities. If you agree, we will keep your personal data on file for up to 12 months for this purpose.
If your application for employment is successful, your personal data will be processed in accordance with our Privacy Notice for UK Co-Workers and Contractors, a copy of which is available on request.
Your rights
Individuals whose personal data is processed by IHIA have certain legal rights in respect of the information. These include:
- request access to or correction of your personal data;
- request the erasure of your personal data;
- request the restriction of the processing of your personal data;
- withdraw your consent where IHIA obtained your consent to process personal data (without this withdrawal affecting the lawfulness of processing prior to the withdrawal);
- request data portability (such as the right to receive any Personal Data you have provided to IHIA in a structured, commonly used and machine-readable format, as well as to require IHIA to transmit it to another controller when technically feasible);
- object to the processing of your personal data for direct marketing purposes; and
- object to the processing of your personal data for other purposes in certain cases where IHIA processed your personal data on another legal basis than your consent.
If you would like to exercise any of these rights, please contact PDPC(s). IHIA will honour any of the above requests, withdrawal or objections as required under the applicable data protection laws but not all of these rights are absolute; they do not always apply, and sometimes exemptions may be engaged. We may, in response to a request, ask you to verify your identity and/or provide information that will help us to understand your request better. If we do not comply with your request, we will explain why.
If you are not satisfied with our response, you have the right to make a complaint to the UK Information Commissioner (www.ico.org.uk).
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to IHIA during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Updates
This notice may be updated periodically and without prior notice to reflect changes in IHIA’s personal information practices. IHIA will post the updated version on its website and indicate at the top of the notice when it was most recently updated.