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What is the purpose of this document?
ABAC Center of Excellence Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes 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. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR). If you have questions regarding your personal data and how we use it, please contact our Compliance Department (acting as DPO) using the contact details below:
Huma Khalid – Sr. Compliance Officer; email@example.com
Nadira Tabassum- Legal Counsel; firstname.lastname@example.org
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
Lawful basis for processing
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
ABAC Center of Excellence Limited’s contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll; bank account; postal address; sick pay; leave; maternity pay; and pension and emergency contacts.
Our statutory responsibilities are those imposed on the company by legislation. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax; national insurance; statutory sick pay; statutory maternity pay; family leave; work permits; and equal opportunities monitoring.
ABAC Center of Excellence Limited has a legitimate interest in processing personal data during employment. Processing data from employees allows us to manage the employment relationship. Our management responsibilities are those necessary for the organizational functioning of the company. The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment; training and development; absence; disciplinary matters; health and safety; security, e-mail address and telephone number; and criminal convictions. We may also need to process data from employees to respond to and defend against legal claims.
– Where we need to protect your interests (or someone else’s interests)- Where it is needed in the public interest (or for official purposes)
How we use personal sensitive information
‘Special categories’ of particularly sensitive personal information requires high levels of protection. We need to have further justification for collecting, storing and using this type of personal information.
ABAC Center of Excellence Limited may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, physical and mental health, disability, criminal allegations, proceedings or convictions, in the following circumstances:
In limited circumstances, with your explicit written consent.
We will use your sensitive personal information in the following ways:
The kind of information we hold about you
The types of personal data we collect
If you fail to provide personal 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 a credit check 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
Information about criminal convictions
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the work (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out a criminal record check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.]
How we collect your personal data
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Data sharing- Who has access to your personal data
Your information may be shared internally for the purposes of managing the employment relationship. This includes members of the HR and recruitment team, training team, managers and IT staff if access to the data is necessary for the performance of their roles.
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We require third parties to respect the security of your data and to treat it in accordance with the law.
We may also share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
All our third-party service providers 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.
Data security- How we protect your personal data
ABAC Center of Excellence Limited is committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected from unauthorised access and improper use.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For further details please email the Compliance Department. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify any applicable regulator of a breach where we are legally required to do so.
ABAC Center of Excellence Limited recognises that some countries do not have the same standard of data protection afforded in most EU States, for this reason ABAC Center of Excellence Limited has a strict supplier management policy which includes the screening of all new suppliers, annual security questionnaires and reviews, and the use of formal processing agreements. Our processing agreements also include terms dictating that the suppliers:
We may also transfer your data to the USA. The USA has weaker data protection laws than that of the EEA and therefore we will ensure that only organisations who are a part of the EU-US Privacy Shield initiative will handle your personal data. More details on this certification can be found at www.privacyshield.gov/welcome.
Data retention- How long will you use my information for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Details of retention periods for different aspects of your personal information are available in our retention policy which is available from Compliance Department and Human Resource Department. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Your rights as a Data Subject- Rights of access, correction, erasure, and restriction
Under certain circumstances, by law you have the right to:
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 Compliance Department in writing.
Right to withdraw consent
When you applied for this role, you provided consent on [DATE] 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 the Compliance Department. 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.
Change of purpose
We will only use your personal data for the purposes for which we collected it. Please note we may process your personal data without your knowledge or consent, where this is required or permitted by law.
Data Protection Officer
We have appointed Compliance Team as 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 Compliance Team. 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.]
Right to Complaint
You have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office – please refer to its website at www.ico.org.uk. You may contact the Information Commissioner’s Office as follows:
By email: Please complete the form at https://ico.org.uk/global/contact-us/email/
By phone: 0303 123 1113
By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5A