CANDIDATE PRIVACY POLICY

You have contacted or previously contacted us about potential positions, submitted your CV to us or Maetrics has contacted you about a potential position which you have discussed and shown interest in.

The Company (collectively, Maetrics LLC, Maetrics Ltd and Maetrics GmbH) is committed to processing your data securely and transparently. This privacy notice sets out the types of data that we collect and hold on you as a candidate or job applicant. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

The Company is additionally aware of its obligations to residents and citizens of the EU and UK under the General Data Protection Regulation (GDPR) and this privacy notice complies with the requirements of GDPR.

This notice applies to all individuals who the company has had correspondence with regarding potential work or job opportunities. Individuals may have approached the company or been approached by the company.

Data controller details
The Company is a data controller, meaning that it determines the processes to be used when using your personal data. The company has appointed Data Protection Officers who are responsible for ensuring your data is stored and processed in accordance with this privacy notice. Data Protection Officers can be contacted at dpo@maetrics.com.

Data protection principles
In relation to your personal data, we will:
• process it fairly, lawfully and in a clear, transparent way
• collect your data only for reasons that we find proper for the course of your potential employment in ways that have been explained to you
• only use it in the way that we have told you about
• ensure it is correct and up to date
• keep your data for only as long as we need it
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.

Types of data we process
We may hold many types of data about you depending on the length of our dialogues together regarding job opportunities:
• your personal details including your name, address, date of birth, e-mail address, phone numbers
• your photograph
• gender
• marital status
• information included on your CV/resume/application including qualifications, references, education history and employment history
• information about your current level of remuneration, including benefit entitlements and your future expectations
• information about selection decisions for your application including shortlisting, interview notes, personality profiles and other selection activity performance data
• documentation relating to your right to work in the countries we operate in
• details of your criminal record
• non-disclosure agreements we have with you

How we collect your data
We collect data about you in a variety of ways including the information you would normally include in a CV/resume or a job application cover letter, from your LinkedIn and/or job board profile or notes made by our recruiting officers during a recruitment interview and other selection activities. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.

In some cases, we will collect data about you from third parties, such as employment or recruitment agencies, former employers when gathering references, credit reference agencies or criminal records checks where appropriate.

Personal data is kept in recruitment files or within the Company’s CRM, Applicant Tracking and IT systems.

Why we process your data
The law on data protection allows us to process your data. For those in the EU and UK, GDPR allows us to process your data for certain reasons which are detailed below. The same reasons are applicable globally:
• in order to perform the employment/sub-contractor contract that we are party to
• in order to carry out legally required duties
• in order for us to carry out our legitimate interests
• where we have your consent to do so
• to protect your interests and
• where something is done in the public interest.

All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first four reasons set out above to process your data.

We need to process data 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. We need to collect your data to ensure we are complying with legal requirements such as:
• carrying out checks in relation to your right to work in the countries where you will be working
• making reasonable adjustments for disabled candidates

We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:
• ensuring confidentiality
• making decisions about who to offer employment/work to
• making decisions about salary and other benefits
• assessing training needs
• keeping in touch with you for future employment opportunities
• dealing with legal claims made against us

If you are unsuccessful in obtaining employment, as we operate in such a specific sector, we will hold your data to make contact with you in case other suitable job vacancies arise in the Company for which we think you may wish to apply.

Special categories of data
Special categories of data are data relating to your:
• health
• sexual orientation
• race
• ethnic origin
• political opinion
• religion
• trade union membership and
• genetic and biometric data

We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
• you have given explicit consent to the processing
• we must process the data in order to carry out our legal obligations
• we must process data for reasons of substantial public interest
• you have already made the data public

We will use your special category data:
• to consider reasonable adjustments for disclosed disabilities in relation to our application, selection and offer processes

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment should you be successful in obtaining employment. We use criminal conviction data in the following ways:
• to assess suitability in a role
• to fulfil contractual obligations

We rely on the lawful basis that it is necessary for carrying out obligations under employment to process this data.

If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your application in the absence of this information.

Sharing your data
Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, Company managers, Recruiters, HR, those in the department where the vacancy is who responsible for screening your application and interviewing you. Your data may also be shared externally with our clients for purposes of assessing your suitability for a role, and/or IT contractors where you require access to our systems and our HR consultants who may support us in our recruitment and selection processes.

In some cases, we will collect data about you from third parties, such as employment or recruitment agencies.

Your data will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data in order to obtain references, personality profiling, to obtain a criminal records check or credit check as appropriate as part of the recruitment process.

As a globally operating organisation with headquarters based in the USA, the Company may be required to transfer personal data to countries outside of the USA and outside of the EEA. We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by data protection laws including GDPR:
• Using IT systems with GDPR security assurance to access data from overseas
• Using encryption if sending high risk data by email
• GDPR training for non EEA data processors
• Procedures for storing and processing data to GDPR standards in non EU and UK countries.

Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. E.g. backing up our servers, firewalls, access control for personal information, using password protected documents and encryption when transferring sensitive data, hard drive encryption on all laptops, ensuring our IT systems that process personal information are secure to GDPR standards.

Where we share your data with third parties, we provide written instructions to them to ensure that your data is held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data. Where needed, a separate Non Disclosure Agreement (NDA) is also signed.

Where we share you CV/resume with clients for business development purposes, we ensure that the client is aware of their obligations to ensure the security of your data.

How long we keep your data for
For residents and citizens of the EU and UK, under GDPR, we only keep your data for as long as we need it for and this will depend on whether or not you are successful in obtaining employment/work with us. If your application is not successful we will keep your data for the purpose of contacting you for future work opportunities for a period of 5 years once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you grant us specific consent to our processing of your data for a further period.

For those who are not in the EU or UK, if your application is not successful we will keep your data indefinitely for the purpose of contacting you for future work opportunities.

In all cases, if your application is successful, your data will be kept and transferred to the systems we administer for employees, workers and sub-contractors. We have a separate privacy notice for employees, workers and sub-contractors, which will be provided to you.

Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

Your rights in relation to your data
GDPR gives EU and UK citizens and residents certain rights in relation to the data we hold. Although not a right for non EU and UK citizens and residents, we extend these privileges to all. These are:
• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
• the right to portability. You may transfer the data that we hold on you for your own purposes
• the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
• the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact the Data Protection Officers listed above.

Making a complaint
If you think your data protection rights under GDPR have been breached in any way by us, you are able to make a complaint to a supervisory authority in the EU. In the UK, the supervisory authority is the Information Commissioner (ICO): ico@org.uk.