Data privacy for candidates
Introduction
The Redpin Group (“Redpin”, “we”, “our” or “us”) provides this notice to you because you are applying to work with us as an employee, worker or contractor.
This notice sets out the basis on which we will process your personal data. Please read it carefully to understand our practices regarding your personal data and how we will use it.
About Us
Currencies Direct Limited ( a member of the Redpin Group) is the controller of the personal data of prospective employees, workers and contractors, and is subject to applicable data protection laws.
If you have any questions about this notice or your personal data, or wish to exercise any of your rights as described in this notice or under applicable data protection laws, you can contact us through [email protected]
What types of personal data are protected?
Personal data
This notice applies to your “personal data”. This is any information relating to you as an identified or identifiable person or which allows you to be identified as an individual.
‘Special categories of personal data’ (United Kingdom (UK) and European Economic Area (EEA) countries) or ‘sensitive personal data’ in other countries
Within the broad range of information which can be personal data, information revealing the following characteristics is considered a“special category of personal data” in the UK and EEA and is therefore subject to a greater degree of protection:
physical or mental health;
racial or ethnic origin;
political opinions;
trade union membership;
religious or philosophical beliefs;
sexuality or sexual life; and
genetic and biometric data.
Outside of the UK and EEA, other types of sensitive personal data, in addition to the “special categories of data” mentioned above, may include:
social status;
criminal history;
membership of a professional or trade association;
social security numbers;
bank account information; and
financial data.
What personal data we collect
Personal data you give us
You may give us personal data about you by filling in forms online or by phone, email, in person, or otherwise, by supplying a CV or through a recruitment agency or other third party or through the interview process.
Personal data we collect from you
The personal data that we collect about you includes, but is not limited to, the following:
your name;
home address;
contact details (such as telephone number and email address);
date of birth;
gender;
marital status;
your image or a recording of you;
copies of your passport, driving licence and similar documents;
education history (including copies of relevant degrees, diplomas or certificates if required), training and professional experience;
current and past employment details;
immigration status and work permits;
languages spoken and level of proficiency;
psychometric and other test results;
criminal record information (where required or permitted by local laws);
information required to prepare the employment contract;
other information given in your CV;
interview notes and recordings;
diversity information (such as information about your race or ethnicity); and
information about your health, such as any disability you might have.
Personal data provided by third parties
We collect most of the personal data described above from you directly.
However, we may also collect personal data about you from third parties, including:
existing Redpin Group employees who refer or nominate you for roles with us;
governmental authorities (such as local tax authorities and, in the UK, the Disclosure and Barring Service);
your named referees who you’ve asked to provide us with references;
where allowed by law, third-party background screening providers, credit reference agencies, fraud prevention agencies, sanction screening and criminal convictions screening agencies; and
where allowed by law, other publicly available sources, such as social media networking sites (such as LinkedIn, Instagram and Twitter).
Data relating to criminal convictions and offences
Where required and allowed by law, we also collect and store personal data relating to criminal convictions and offences. In cases where we need to identify a lawful basis for such processing, then, depending on local laws, such processing is carried out with your consent, to comply with our legal obligations or on the basis of our legitimate interests (to ensure we hire suitable candidates). This data is only processed where it is necessary for the purposes of:
complying with or assisting other persons to comply with a regulatory requirement which involves us taking steps to establish whether you have committed an unlawful act or been involved in dishonesty, malpractice or other seriously improper conduct;
preventing or detecting unlawful acts (including fraud);
any legal proceedings (including prospective legal proceedings);
obtaining legal advice; or
establishing, exercising or defending legal rights.
If you fail to provide us with personal information
If you fail to provide information when requested by our HR team, or refuse permission to contact referees or to conduct screening or criminal records checks, we will not be able to process your application successfully.
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What we do with your personal data and our legal basis
We process your personal data for the reasons listed below. In some countries we require a lawful basis to process your personal data and therefore we have also identified this below.
Purpose of processing | Lawful basis |
Assessing your skills, qualifications, and suitability for the role, including taking up references and conducting appropriate background checks. | Legitimate interests (to ensure we hire suitable candidates) |
Recruitment processes (including negotiation and communicating with you in relation to your application). | Legitimate interests (to run a fair and efficient recruitment process). |
Complying with our legal and regulatory obligations, including for the purposes of:
| Compliance with legal obligations. |
Recording interviews for quality control purposes and to train our interviewers. | Depending on local laws, either legitimate interests (to monitor the quality of our interviewers) or your consent. |
Carrying out equal opportunities monitoring. | Consent. |
Carrying out analytics in relation to our recruitment practices. | Legitimate interests (to ensure we can improve our recruitment practices where necessary). |
Dealing with any legal disputes involving you or other prospective, current or former employees, workers or contractors. | Legitimate interests (to establish, exercise or defend ourselves against legal claims) . |
Quality assurance, monitoring and staff training purposes. | Legitimate interests (to ensure our recruitment practices are carried out properly). |
Promote the safety and security of our personnel (including by detecting and stopping threats to our personnel and property). | Legitimate interests (to ensure the wellbeing and safety of our staff). |
Please note that the lists of processing activities included in this section are not exhaustive. They are illustrative of the different types of processing that we may undertake. Please contact our Data Protection Officer at [email protected] if you have a question about whether we process your personal data for a specific purpose not listed in this section.
‘Special categories of personal data’ or ‘sensitive personal data’
We process ‘special categories of personal data’ or ‘sensitive personal data’ (as described above) for the purposes of:
carrying out the obligations we have to exercise our and your specific rights which are imposed by employment laws;
establishing, bringing or defending legal claims; and
in the case of personal data about your physical or mental health, to enable us to assess your working capacity and take decisions for occupational health purposes.
In the case of “equal opportunities monitoring”, please note that participation is voluntary and providing this information is optional. Any information you provide will not be accessible or used in the hiring process, and has no effect on your opportunity for employment.
Disclosure of your personal data to third parties
For the purposes set out in the chart above, we may share your personal data with:
our group companies where necessary to process your application;
the colleagues and team-members you may be asked to work with if you join us;
professional advisors (including lawyers, accountants and auditors) where necessary to receive their services;
legal and regulatory authorities (such as tax authorities) where necessary to comply with our legal obligations;
our third party service providers, including our data hosting service provider, background screening check provider and online recruitment and testing service providers. Our online recruitment platform-provider is Greenhouse Software Inc., a cloud services provider based in the United States. Consequently, your personal data may be transferred to and processed within the United States, subject to appropriate data transfer and data privacy safeguards being in place.
We also disclose your personal data to third parties where it is in our legitimate interest to do so, including for the following reasons:
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
if all or substantially all of our assets are acquired by a third party, in which case personal data held about our applicants will be one of the transferred assets; and
if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation.
Except as set out in this notice, or as required by law, we do not sell your personal data or disclose it to any third parties without your consent.
Security of your personal data
We are committed to ensuring that your personal data is safe and take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this notice.
Unfortunately, the transmission of personal data through the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to or stored on our IT system, and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
If we share your personal data with any third party, we will take all necessary steps to make sure that the third party commits to handling your personal data lawfully and securely.
How long we keep your personal data
We will keep your personal data for as long as necessary to fulfil the purposes described in this notice or the terms of any contract that we enter into, or for such longer period as may be required by law. After this, where allowed by laws and this notice, we will erase or anonymise your personal data. If you need any additional information about this, please contact us at: [email protected].
Your rights
Subject to applicable laws in your location, you may have the following rights in relation to your personal data:
the right to access personal data which we hold about you;
the right to ask us to correct your personal data if you think it's wrong;
the right to ask us to delete your personal data in certain circumstances;
the right to object to us processing your personal data on the basis of our legitimate interests or another lawful basis;
the right to ask us to restrict how we use your personal data in certain circumstances;
the right to ask us to transfer personal data to you or another company in a structured, commonly used, machine-readable format in certain circumstances;
the right to withdraw your consent (where you have previously given us this); and
the right to ask us to carry out a human review of an automated decision we make about you.
Please note that not all of these rights are absolute and we may not be required to comply with your request where exemptions apply under applicable data protection laws.
Exercising your rights
You can exercise any of your rights as described in this notice and under data protection laws by contacting us through [email protected]
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
We will endeavour to respond to your request within the time period mandated by applicable law. In the UK and the EEA, this means that we will endeavour to respond to your request within one month. Please note, however, that this time period may be extended in some cases.
International transfers
Your personal data will be stored on servers located in the United States, UK or EEA.
Where required by applicable laws, your consent to the transfer of your personal data outside your home country will be obtained as part of your application.
As an international organisation, authorised personnel may access your personal data in any country in which we operate. Therefore, it may be necessary to transfer your details to members of our group located in countries that may not have equivalent data protection or privacy laws to those which apply in your own country. We may also need to transfer your personal data to third party service providers located in other countries.
Regardless of where your personal data is transferred, we shall put in place appropriate safeguards to ensure that your personal data is treated securely and in accordance with applicable law. For individuals in the EEA and UK, this usually means entering into Standard Contractual Clauses or an International Data Transfer Agreement with the recipients of your data who are located in countries which are not recognised as having adequate data protection laws. More details regarding these safeguards can be obtained by emailing: [email protected]
Complaints
Please direct any complaints about how we process your personal data to our Data Protection Officer via [email protected].
You also have the right to complain to your local data protection authority. In the UK, that is the Information Commissioner’s Office who can be contacted on 0303 123 1113 or via their website
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Changes
This notice may be amended by the Redpin Group at any time. You can always find the latest version of this notice on our website.
How to Contact Us
If you have a privacy concern or question related to this privacy notice, please contact [email protected]
Our address is:
Redpin Group
HR Privacy
One Canada Square
Canary Wharf
London E14 5AA
Telephone: (+44) 20 7847 9446