You are being provided with this Privacy Notice because you are making an application to join ESKAD LLC or one of its clients or affiliated companies (“Company, ‘“we, “us”, “our”) as an employee, fixed term worker or contractor. In order to carry out our recruitment process, we collect certain personal data relating to candidates. In doing so, Company acts a "controller"; meaning that we are responsible for deciding how your personal information is used and stored. We use an applicant tracking platform, Recruitee, to manage the recruitment process. Recruitee will be the “processor” of your personal data, meaning that they will be responsible for the processing of your personal data on our behalf.
This Privacy Notice will make 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 as we are committed to being transparent about how your data is used, stored, transferred and retained. It also provides you with certain information that is required to be provided under applicable data protection laws, including the Law of Georgia on Personal Data Protection and details how we shall be meeting our data protection obligations in accordance with these laws.
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 the purposes of recruitment 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.
· Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application to work with us and the recruitment process in general, we will collect, store, and use the following categories of personal information about you and this shall be handled and stored on the Recruitee platform:
· The information you have provided to us in your curriculum vitae (CV) and/or covering letter including information about your skills, experience and employment history;
· The information you have provided on our application form, including but not limited to, your name, title, address, telephone number, personal email address, if applicable right to work in Georgia, employment history and qualifications.
· Health information to ensure we fulfil our duty of care;
· Information relating to criminal processes or convictions.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
· You, the candidate;
· Information from your passport or identity documents;
· application form;
· CV;
· Information collected through interviews or other forms of assessment;
· Third parties such as references supplied by former employers, information from employment background check providers, and information from criminal record checks (if applicable). We will only seek information from a third party once a job offer has been made to you, and we shall inform you we shall be doing so.
This information is collected and stored within the Recruitee applicant tracking platform.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
· Assess your skills, qualifications, and suitability for the relevant role in advance of us entering into a contract of employment, or otherwise, with you.
· Carry out background and reference checks, if applicable.
· Communicate with you about the recruitment process.
· Keep records related to our hiring processes.
· Comply with our legal or regulatory requirements.
It is in our legitimate interests to process your personal data during the recruitment process to manage the process. It is required to assess and confirm your suitability for the role that we are recruiting for to determine whether to appoint you to a role, since any such appointment would be beneficial to the success of our business. It is important for us to process your personal information in order to enable us to subsequently decide whether to enter into a contract of employment, or otherwise, with you. We may also need to process data from candidates to respond to and defend legal claims.
Information about criminal convictions
We do not envisage that we will process information about criminal convictions however, there may be some roles that require a basic disclosure of your criminal records history. We have in place appropriate safeguards which we are required by law to maintain when processing such data.
Recruitment processes are not based solely on automated decision making.
Your information will be shared for the purpose of the recruitment process only and will include sharing, via the Recruitee system, with members of our team who may need to access the personal information for the performance of their roles.
FAILURE TO PROVIDE PERSONAL INFORMATION
You are under no statutory or contractual obligation to provide your personal information to us during the recruitment process however, If you fail to provide personal information which is necessary for us to consider your application when requested (such as evidence of qualifications or work history), we will not be able to process your application successfully.
STORAGE OF PERSONAL DATA
All personal data provided by a candidate will be stored securely on the Recruitee platform and processing of the data by Company employees shall only take place within the Recruitee environment. Recruitee may engage with sub-processors within the European Union to support certain features integrated into the platform and they may therefore, have access to, or process your personal data accordingly. Recruitee may however, only engage a sub-processor if it has imposed, in writing, the necessary responsibilities and obligations on the sub-processor as required by Article 16 of Law of Georgia on Personal Data Protection. In the event that Recruitee removes or appoints other suitable sub-processors, they shall do so in accordance with Article 16 of Law of Georgia on Personal Data Protection and solely upon providing us with at least six weeks’ notice of any such changes.
DATA SHARING AND TRANSFER
Why might you share my personal information with third parties?
Other than Recruitee’s sub-processors, we will share your personal information with a third party providing an e-signature tool for the recruitment process.
In the event that your application is successful and an offer of employment is made, in line with the Article 11 of the Labour Code of Georgia, we may need to share your personal information with background check service providers to obtain necessary background checks, or, with former employers to obtain references. We may otherwise need to share your personal information with third parties in the event of defending a legal claim, or for audit purposes.
All of our third-party service providers and other applicable group companies are required to take appropriate security measures to protect your personal information in line with our policies. 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.
Third Country Data Transfers
Recruitee will not transfer your personal data to any country outside of the European Economic Area (EEA).
Company and Recruitee have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
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.
How long will you use my information for?
In the event that we extend a conditional offer of employment to you in relation to a role, we will request your explicit consent to retain your personal information relating to your application for a period of 12 months. We will retain your personal information 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. When this period elapses, we will seek further written consent from you to retain your data for an additional 12-month period for additional transparency and safeguarding with regard to our recruitment process. Your personal information will be transferred to your electronic personal file and retained during your employment.
In the event that you do not consent to such retention of your personal data, we shall then securely destroy your personal information in accordance with our data retention policy.
If you are unsuccessful in being offered an appointment to a role, we will write to you seeking your explicit consent to retain your personal information on file for 12 months, on the basis that a further opportunity may arise in future and we may wish to consider you for that. Following this period, we will seek further written consent from you to retain your data for an additional 12-month period. If you refuse consent in either circumstance, we will securely destroy any personal data we hold in relation to you once we receive and process your refusal.
YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION
As a data subject, by law you may be entitled to one or more of the following rights:
· Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
· Request update of the personal information. This enables you to request to update any personal information that has been changed.
· Request addition to the personal information. This enables you to request to add specific personal information to the personal information being processed.
· Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
· Object to processing of your personal information 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 information for direct marketing purposes.
· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
· Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact dataprotection@eskadservices.com in writing.
· Right to withdraw consent – In applying for a role with us, you consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact dataprotection@eskadservices.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.
DATA PROTECTION CONTACT
For any queries relating to this privacy notice, compliance with it, or relating to how we handle your personal information, please contact dataprotection@eskadservices.com You have the right to make a complaint at any time to the Personal Data Protection Service, who is responsible for handling data protection issues in Georgia.
You are being provided with this Privacy Notice because you are making an application to join ESKAD LLC or one of its clients or affiliated companies (“Company, ‘“we, “us”, “our”) as an employee, fixed term worker or contractor. In order to carry out our recruitment process, we collect certain personal data relating to candidates. In doing so, Company acts a "controller"; meaning that we are responsible for deciding how your personal information is used and stored. We use an applicant tracking platform, Recruitee, to manage the recruitment process. Recruitee will be the “processor” of your personal data, meaning that they will be responsible for the processing of your personal data on our behalf.
This Privacy Notice will make 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 as we are committed to being transparent about how your data is used, stored, transferred and retained. It also provides you with certain information that is required to be provided under applicable data protection laws, including the Law of Georgia on Personal Data Protection and details how we shall be meeting our data protection obligations in accordance with these laws.
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 the purposes of recruitment 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.
· Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application to work with us and the recruitment process in general, we will collect, store, and use the following categories of personal information about you and this shall be handled and stored on the Recruitee platform:
· The information you have provided to us in your curriculum vitae (CV) and/or covering letter including information about your skills, experience and employment history;
· The information you have provided on our application form, including but not limited to, your name, title, address, telephone number, personal email address, if applicable right to work in Georgia, employment history and qualifications.
· Health information to ensure we fulfil our duty of care;
· Information relating to criminal processes or convictions.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
· You, the candidate;
· Information from your passport or identity documents;
· application form;
· CV;
· Information collected through interviews or other forms of assessment;
· Third parties such as references supplied by former employers, information from employment background check providers, and information from criminal record checks (if applicable). We will only seek information from a third party once a job offer has been made to you, and we shall inform you we shall be doing so.
This information is collected and stored within the Recruitee applicant tracking platform.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
· Assess your skills, qualifications, and suitability for the relevant role in advance of us entering into a contract of employment, or otherwise, with you.
· Carry out background and reference checks, if applicable.
· Communicate with you about the recruitment process.
· Keep records related to our hiring processes.
· Comply with our legal or regulatory requirements.
It is in our legitimate interests to process your personal data during the recruitment process to manage the process. It is required to assess and confirm your suitability for the role that we are recruiting for to determine whether to appoint you to a role, since any such appointment would be beneficial to the success of our business. It is important for us to process your personal information in order to enable us to subsequently decide whether to enter into a contract of employment, or otherwise, with you. We may also need to process data from candidates to respond to and defend legal claims.
Information about criminal convictions
We do not envisage that we will process information about criminal convictions however, there may be some roles that require a basic disclosure of your criminal records history. We have in place appropriate safeguards which we are required by law to maintain when processing such data.
Recruitment processes are not based solely on automated decision making.
Your information will be shared for the purpose of the recruitment process only and will include sharing, via the Recruitee system, with members of our team who may need to access the personal information for the performance of their roles.
FAILURE TO PROVIDE PERSONAL INFORMATION
You are under no statutory or contractual obligation to provide your personal information to us during the recruitment process however, If you fail to provide personal information which is necessary for us to consider your application when requested (such as evidence of qualifications or work history), we will not be able to process your application successfully.
STORAGE OF PERSONAL DATA
All personal data provided by a candidate will be stored securely on the Recruitee platform and processing of the data by Company employees shall only take place within the Recruitee environment. Recruitee may engage with sub-processors within the European Union to support certain features integrated into the platform and they may therefore, have access to, or process your personal data accordingly. Recruitee may however, only engage a sub-processor if it has imposed, in writing, the necessary responsibilities and obligations on the sub-processor as required by Article 16 of Law of Georgia on Personal Data Protection. In the event that Recruitee removes or appoints other suitable sub-processors, they shall do so in accordance with Article 16 of Law of Georgia on Personal Data Protection and solely upon providing us with at least six weeks’ notice of any such changes.
DATA SHARING AND TRANSFER
Why might you share my personal information with third parties?
Other than Recruitee’s sub-processors, we will share your personal information with a third party providing an e-signature tool for the recruitment process.
In the event that your application is successful and an offer of employment is made, in line with the Article 11 of the Labour Code of Georgia, we may need to share your personal information with background check service providers to obtain necessary background checks, or, with former employers to obtain references. We may otherwise need to share your personal information with third parties in the event of defending a legal claim, or for audit purposes.
All of our third-party service providers and other applicable group companies are required to take appropriate security measures to protect your personal information in line with our policies. 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.
Third Country Data Transfers
Recruitee will not transfer your personal data to any country outside of the European Economic Area (EEA).
Company and Recruitee have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
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.
How long will you use my information for?
In the event that we extend a conditional offer of employment to you in relation to a role, we will request your explicit consent to retain your personal information relating to your application for a period of 12 months. We will retain your personal information 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. When this period elapses, we will seek further written consent from you to retain your data for an additional 12-month period for additional transparency and safeguarding with regard to our recruitment process. Your personal information will be transferred to your electronic personal file and retained during your employment.
In the event that you do not consent to such retention of your personal data, we shall then securely destroy your personal information in accordance with our data retention policy.
If you are unsuccessful in being offered an appointment to a role, we will write to you seeking your explicit consent to retain your personal information on file for 12 months, on the basis that a further opportunity may arise in future and we may wish to consider you for that. Following this period, we will seek further written consent from you to retain your data for an additional 12-month period. If you refuse consent in either circumstance, we will securely destroy any personal data we hold in relation to you once we receive and process your refusal.
YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION
As a data subject, by law you may be entitled to one or more of the following rights:
· Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
· Request update of the personal information. This enables you to request to update any personal information that has been changed.
· Request addition to the personal information. This enables you to request to add specific personal information to the personal information being processed.
· Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
· Object to processing of your personal information 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 information for direct marketing purposes.
· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
· Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact dataprotection@eskadservices.com in writing.
· Right to withdraw consent – In applying for a role with us, you consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact dataprotection@eskadservices.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.
DATA PROTECTION CONTACT
For any queries relating to this privacy notice, compliance with it, or relating to how we handle your personal information, please contact dataprotection@eskadservices.com You have the right to make a complaint at any time to the Personal Data Protection Service, who is responsible for handling data protection issues in Georgia.