Version: March 2022

About this notice

Cielo Talent is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. This Recruitment Candidate Privacy Notice makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise (whether as an employee, worker or contractor), and how long it will usually be retained for.

When we refer to Data Protection Legislation it means, but not exclusive to, the GDPR, UK Data Protection Act, Singapore and Argentina PDPA, CCPA, PIPEDA, LGPD, Hong Kong Ordinance and any other jurisdictional privacy framework implemented in connection with the aforementioned legislation.

Where data is processed of applicants in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time, if not referenced above.

Data protection principles

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 valid purposes that we have clearly explained to you 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, we will collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your application or profile submission
• Any information you provided in an email during the recruitment process
• Any information you provide to us during an interview
• Test scores for those candidates who complete an assessment
• Overall candidate scores for all the personal and professional attributes of a candidate when considering them for the position they are applying for
• Information collated during pre-employment vetting checks

We may also collect, store and use sensitive information about your health, including any medical condition, health and sickness records provided to us during the recruitment process.

How we collect your data

We collect personal information about job applicants and prospective candidates from the following sources:

• You, the as job applicant or prospective candidate
• Social Media platforms such as LinkedIn and CV databases
• Recruitment consultants

How we use information about you

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role
• Carry out background and reference checks, where applicable
• Communicate with you about the recruitment process
• Keep records related to our hiring processes
• With your consent, retain your profile to match you against future opportunities
• Comply with legal or regulatory requirements

It is in our legitimate interests to decide whether to appoint you in the role since it would be beneficial to our business to appoint someone suitable based on the job description and requirements.

We also process your personal information to decide whether to enter into a contract of employment with you.

Having received your CV and application we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role.

If we decide to invite you to an interview, we will use the information provided during the assessment to determine your suitability for the role. If we decide to offer you the role, we will then verify your right to work and take up references if required before confirming your appointment.

Failure to provide information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require details on a certification or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How we use particularly sensitive personal information

If you disclose sensitive personal information, such as health data, during the shortlisting or interview process we will use your particularly sensitive personal information in the following ways:

• to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview or as part of the role you are applying for.

Information about criminal vetting checks

For certain roles, we might request you to undertake a criminal convictions’ check. This service will be carried out by a third party.

We will not keep any photocopy or other image of the criminal check certificate. However, we may keep a record of the date of issue of a certificate, the name of the subject, the type of certificate requested, the position for which the certificate was requested, the unique reference number of the certificate and the details of the recruitment decision taken.

The record will be stored in a secure, access restricted information system for no longer than 6 months from receipt.

Certificate information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.

Automated decision-making

We do not solely use automated decision making for decisions that will have a significant impact on you.

Data sharing

We also use third party recruitment platforms and job boards for posting of advertisements on our behalf. If you have applied via a job board, the portal will be the data controller for your information. All our technology partners have been vetted for compliance with privacy regulations and information security practices.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized 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.

Data retention

We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to the role. We 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. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If we wish to retain your personal information on our systems, on the basis that a further opportunity may arise in future and for your profile to be matched to you, we will seek your explicit consent to retain your personal information for a fixed period on that basis. You can revoke your consent at any time.

Rights of Access, Correction, Erasure and Restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• 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 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 us in writing at privacy.office@cielotalent.com.

Data Protection Officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at privacy.office@cielotalent.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, or the equivalent supervisory authority in the country where you live.

You may also access Cielo’s Privacy Notice and Cookie Policy.