Recruitment Privacy Policy

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  1. Introduction

PQShield Ltd (PQShield, we, us) is the data controller for the information you provide during the recruitment process unless otherwise stated.

As part of the recruitment process, PQShield gathers and handles personal data about job applicants. PQShield is committed to being clear about how we collect and use data, as well as respecting our data protection commitments.

We only process your personal data insofar as this is permitted under the provisions of:

  • UK Data Protection Act 2018;
  • GDPR General Data Protection Regulation (Regulation (EU) 2016/679) (‘GDPR’);
  • Federal Data Protection Act (BDSG) (Germany);
  • General Data Protection Regulation Implementation Act (UAVG) (Netherlands);
  • Wet justitiële en strafvorderlijke gegevens (the Judicial and Criminal Data Act) & VOG (“Verklaring Omtrent het Gedrag”) (Netherlands);
  • French Data Protection Act No. 2018-493 of 20 June 2018 and Decree No. 2019-536 of May 29, 2019

2. Definitions

‘Personal data’ means any information relating to an identified or identifiable natural person (hereinafter referred to as “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by EU or local country law, the controller or the specific criteria for its nomination may be provided for by EU or local country law.

3. What data is collected?
PQShield collects information about you that is required for the recruitment process. This may include but is not limited to: your name, contact information, qualifications, skills, education and qualifications, right to work and your employment history, including information about your current remuneration and benefit entitlements.
This information may be acquired through our recruitment platform, in application forms, from your CVs and cover letter, or through interviews or other means of evaluation, including online assessments.
PQShield may collect equal opportunities data on applicants to track how successful different groups are in being hired by PQShield. Equal opportunities information PQShield collects from applicants will not be used in the hiring process or made available to the hiring manager.

4. How is data used
PQShield must process your data in order to carry out an effective recruitment process, and in the case of your application being successful, to proceed with entering into an employment contract with you.

In some situations, PQShield must process your data to ensure that we are meeting our legal duties. For example, a successful applicant’s right to work must be verified before employment begins, or if you have a disability, we process such information in order to accommodate any necessary changes to the recruitment process, in order to fulfil our obligations and exercise specific employment rights.

PQShield has a legitimate interest in processing personal data during the recruitment process and maintaining records of it. Processing data from job applications allows PQShield to manage the recruitment process, analyse and validate a candidate’s suitability for employment, and to determine who to hire. PQShield may also need to process job applicant data in order to respond to and defend against legal claims.

PQShield will not use your information for any reason other than the recruitment process for which you applied.
If your application is successful, PQShield may also request, receive and process personal information about you from third parties, such as references provided by former employers, information from employment background check providers, and criminal record checks. PQShield will only seek information from third parties after making a conditional job offer to you, and we will notify you of this (and seek your permission where required). Where we seek this information, we do so to fulfil our obligations and exercise specific employment rights.

5. Who has access to data?
Your information may be shared internally within PQShield and with its subsidiaries and any parent companies (together the Group) for the purpose of the recruitment process.

This includes interviewers working in the recruitment process, senior management, and IT professionals who require access to the data to complete their duties.

6. When we may transfer your data overseas
Regardless of where you are located or where the position you are applying for is based, your application will be managed by PQShield Ltd in the UK, and may be transferred overseas to other companies in our Group.

Data we collect will therefore be processed within the UK and the European Economic Area (EEA). There are adequacy regulations in respect of these countries. This means that countries to which we transfer your data are deemed to provide adequate levels of protection for your personal information. Such transfer of personal data to a third country or an international organisation is permitted under Article 45 GDPR if the European Commission has decided that an adequate level of protection exists.

We may transfer personal information we collect about you to other parts of the world outside of the UK and EU where there has not been an adequate decision. This means that countries are not deemed to provide an adequate level of protection for your personal information.
We will transfer your personal data to those countries in limited circumstances that include when a third party supplier (such as IT software supplier) has operations (or provides IT Support for example) in such a country and can only deliver their service to PQShield by transferring your personal data to that country or because their IT infrastructure is structured in such a way that day is stored in those countries.

To ensure that your personal information does receive an adequate level of protection we put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects UK and GDPR legislation.

7. Use of data processors
Data processors are third-party vendors which help us with our recruitment process, such as our recruitment platform. We have contracts with our data processors that include GDPR compliance as part of the terms and conditions. This means that they can’t do anything with your personal information unless we tell them to. They will not disclose your personal information with any company other than us. They will hold it securely and keep it for the time we specify. If your data is being hosted on a third party site, then you will find the provider’s privacy policy on their platform as part of the recruitment process.

8. How is data protected?
PQShield takes the security of your data very seriously, and is certified to ISO 27001. We have internal policies and controls in place to ensure that your data is not lost, mistakenly destroyed, misused, or leaked, and that it is only accessed by our colleagues while performing their jobs.
PQShield stores your data in secure cloud-based services that are only available to company personnel and contractors with a need-to-know basis. Third party data processors are only selected if they have adequate security and data protection policies in place.

9. For how long is data kept?
We will retain employee personal data as long as required for the necessary business purposes or, where reasonably applicable, as long as required to comply with a legal obligation, for archiving purposes or to serve any other legitimate purpose related to that data (e.g. in case of legal holds or pending or expected disputes, or for insurance purposes).
If your job application is successful, the personal information obtained during the recruitment process will be transferred to your personnel file and kept for the duration of your employment. The personnel file is managed by PQShield in the UK and stored on a secure cloud server located in the UK or EU.

10. Your rights
As a data subject, you have several rights. You have the right to access and request a copy of your data, change incorrect or incomplete data, delete or stop processing unnecessary data, and object to processing based on legitimate interests.
If you wish to exercise any of these rights, please contact legal@pqshield.com.
If you believe that we have failed to comply with your data protection rights, you can file a complaints as follows:

  • With the Information Commissioner’s Office if you are based in the UK.
  • If you are based in the Netherlands, you have the right to file a complaint with the Dutch supervisory authority within the meaning of the GDPR, the Autoriteit Persoonsgegevens.
  • If you are based in France, you can lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (the “CNIL”), acting in its capacity as supervisory authority under the regulations in force, either by post (3, Place de Fontenoy, 75007 Paris), or by electronic means.
  • If you are based in Germany, Article 77 (1) of the General Data Protection Regulation (GDPR) grants you the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of personal data concerning you violates the GDPR.

11. Legal basis for the processing of personal data
We only process your personal data insofar as this is permitted under the provisions of the GDPR and, The Data Protection Act 2018 (United Kingdom) and the relevant local data protection laws.

12. What If You Do Not Provide Personal Data?
You have no statutory or contractual obligation to give data to PQShield throughout the recruitment process. However, if you do not supply the requested information, PQShield is unlikely to be able to process your application effectively or at all.

13. Automated Decision Making
PQShield’s recruitment methods do not rely primarily on computerised decision-making.

14. Changes To This Recruitment Privacy Policy
We regularly check our privacy notices. Please check back periodically for any updates or changes to our privacy policy.