EUROMONITOR INTERNATIONAL
DATA PRIVACY NOTICE FOR APPLICANTS
Last updated: September 2024
1.1 This notice is designed to provide information on how Euromonitor International (referred to as “we”, “us” or “our”) processes the personal data of job applicants (referred to as “you” or “your”) who apply to us for a job.
1.2 As a “data controller”, we are responsible for deciding how we process personal data about you. We take your privacy seriously and we are always fully committed to protecting your personal data. We will only process your personal data in accordance with and adhere to the principles (as applicable) contained within, the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (together referred to as “appropriate data protection legislation”).
1.3 This notice does not form part of any offer of employment and we may amend it at any time to reflect any changes in the way in which we process your personal data. If you are in the application process when any changes or updates are made to this notice, we will bring any such changes to your attention as soon as is practicable. We may also notify you in other ways from time to time about the processing of your personal data.
1.4 Our Data Protection Manager (“DPM”) is responsible for ensuring that this privacy notice is maintained. You can contact the DPM at DataProtectionOfficer@Euromonitor.com.
2.1 “Personal data” is any information about a living individual from which they can be identified such as name, location data, any online identifier (such as IP address), or any factor specific to the physical, physiological, genetic, mental, economic or social identity of that person. It does not include data where any potential identifiers have been removed (anonymous data) or data held in an unstructured file.
2.2 There are “special categories” of more sensitive personal data which are more private in nature and therefore require a higher level of protection, such as genetic data, biometric data, information about sex life or sexual orientation, race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health.
2.3 When we refer to “processing”, this means anything from collecting, using, storing, transferring, disclosing, altering or destroying personal data.
3.1 We process your personal data for various reasons, relying on a variety of different bases for lawful processing under appropriate data protection legislation as set out below.
3.1.1 To comply with our legal obligations or exercise legal rights conferred upon us. This may include:
• checks for eligibility to work as required by immigration laws, such as passport and visa documentation;
• formal identification documentation relating to you, such as a passport or driving licence, to verify your identity (including your date of birth);
3.1.2 To pursue our (or a third party’s) legitimate interests as a business. This may include:
• your contact details such as your name, address, telephone number and personal email address which will be used to communicate with you in relation to the recruitment process;
• your CV, any education history, employment records, professional qualifications and certifications for us to consider your suitability for the job you are applying for;
• details of the job role you are applying for any interview notes made by us during or following an interview with you, in order to assess your suitability for that role;
• pay and benefit discussions with you to help determine whether a job offer may be made to you;
• voicemails, emails, correspondence, and other communications created, stored or transmitted by you on or to our computer or communications equipment in order to progress the application through the recruitment process;
• Video recordings and/or call transcriptions whereby we have recorded an interview with yourself for efficiency and continuity reasons;
• CCTV footage of you onsite in our reception areas for security reasons and for the protection of our property; and
• network and information security data in order for us to take steps to protect your information against loss, theft or unauthorised access.
• We may also use this personal data in order to make informed management decisions and for administration purposes.
3.2 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.
3.3 We will only use your personal data for the purposes for which we collected it.
4.1 We also collect, store and use your special category personal data for a range of reasons, relying on a variety of different bases for lawful processing under appropriate data protection legislation, as set out below;
4.1.1 To enable us to perform our legal obligations in respect of employment, social security, social protection law, or needed in the public interest. This may include health information to assess and/or to comply with our obligations under the Equality Act 2010 (for example a requirement to make reasonable adjustments to your working conditions).
4.1.2 For occupational health reasons or where we are assessing your working capability, subject to appropriate confidentiality safeguards. This may include information about your physical or mental health, or disability status, to assess whether any reasonable adjustments are required for you during the recruitment process, carrying out any medical assessment required for your role, pension and any insurance benefits.
4.1.3 To establish, defend or exercise legal claims in an employment tribunal or any other court of law.
4.1.4 For statistical purposes in the public interest such as equal opportunities monitoring (for example the collection of information about race, ethnic origin, sex or religion). Any such information shall only be used, once collected, in an anonymised form for statistical purposes and will not be not used in relation to your application for employment with us.
5.1 We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
6.1 We may obtain data directly from yourselves, where we interact with you via audio and/or video call, via email or through various tools e.g. communication within LinkedIn.
6.2 We may obtain personal data and/or special category personal data about you from third party sources, such as recruitment agencies, job boards, online recruitment platforms, recruitment assessment centres, third parties contracted to assist us with other activities as well as recruitment, occupational health professionals and background check providers. Where we receive such information from these third parties, we will only use it in accordance with this notice.
6.3 In some cases, they will be acting as a controller of your personal data and therefore we advise you to read their privacy notice and/or data protection policy.
6.4 We may share your personal data and special category personal data internally. In particular, it may be shared with: HR employees involved in the recruitment process, employee relations and/or administration of your employment; line managers; consultants; advisers; and/or other appropriate persons who may be involved in the recruitment process for the job(s) you are applying for.
6.5 We may store your data within the systems of our ATS providers (Applicant tracking service) in order to manage the recruitment process. We mainly use Workable but for our candidates based in China we use WeChat.
6.6 We may use AI tools to process your basic personal data. Where we do so, we will ensure that we have carried out a Data Protection Impact Assessment to identify and address any privacy risks.
6.6.1 We rely on our legitimate interests as a lawful basis in order to process your data in this way.
6.6.2 We use AI to assist us with productivity and efficiency, such as the production of: meeting notes/summaries, transcripts, meeting follow-up actions etc. We do this to ensure that we are always improving the service we provide to our candidates by carrying out data analysis and to ensure the efficiency of the recruitment process. We will always manually review any AI generated notes to check for accuracy.
7.1 We may transfer the personal data we collect about you to any of our offices, or third party vendors which may host your data on our behalf, some of which are outside the EEA.
7.2 If we transfer personal data from the European Economic Area to other countries (‘third countries) in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide a similar level of data privacy protection to the standard which is afforded to individuals under GDPR and DPA 2018. In other words, your rights and protections remain with your data.
7.3 We use EU Standard Contractual Clauses and/or UK International Data Transfer Agreement clauses in our agreements and other measures designed to ensure that recipients of your personal data in third countries protect it.
8.1 Your personal data and special category personal data is stored in a variety of locations, including: electronically on our secure servers and in hard copy form in locked filing cabinets.
8.2 We take appropriate technical and organisational security measures and have rules and procedures in place to guard against unauthorised access, improper use, alteration, disclosure and destruction and accidental loss of your personal data.
8.3 In addition, we limit access to your personal data to those who have a business need to know and they will only process your personal data on our instructions and subject to a duty of confidentiality.
8.4 We have put in place procedures to deal with any suspected or actual data security breach and will notify you and the Information Commissioner’s Office (“ICO”) of a suspected breach where we are legally required to do so.
8.5 Whenever we propose using new technologies, or where processing is construed as ‘high risk’, we are obliged to carry out a data protection impact assessment which allows us to make sure appropriate security measures are always in place in relation to the processing of your personal data.
9.1 We keep your personal data and special category personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Information about how long we retain such personal data is set out in Appendix 1.
9.2 When applying for a job with us, we compile and keep an electronic file containing information about you which relates to your application for a job with us. Your information will be kept secure and will be used for the purposes of your job application, as explained above.
9.3 If you are offered and you accept a job with us, your personal data will be transferred to a manual and electronic personnel file.
9.4 In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use and retain such information without further notice to you, as it falls outside of the definition of personal data under appropriate Data Protection legislation.
10.1 We encourage you to ensure that the personal data that we hold about you for the purposes of your application or for the purposes of considering you for any similar roles is accurate and up to date by keeping us informed of any changes to your personal data. You can update your details on our recruitment platform.
11.1 You may make a formal request for access to personal data and/or special category data that we hold about you at any time. This is known as a Subject Access Request. Such a request must be made in writing and we will respond within 1 month. Please note that we are permitted to extend the 1-month time period for responding by an additional 2 months where in our view your request is complex or numerous in nature. We may also charge a reasonable fee based on administrative costs where in our view your request is manifestly unfounded, excessive or a request for further copies. Alternatively, we may refuse to comply with the request in such circumstances. If this is not the case, we will comply with all of our obligations under appropriate data protection legislation.
11.2 Under certain circumstances, by law you also have the right to:
11.2.1 have your personal data corrected where it is inaccurate;
11.2.2 have your personal data erased where it is no longer required. Provided that we do not have any continuing lawful reason to continue processing your personal data, we will make reasonable efforts to comply with your request;
11.2.3 have your personal data be transferred to another person in an appropriate format;
11.2.4 withdraw your consent to processing where this is our lawful basis for doing so. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you withdraw your consent, our use of your personal data which was collected before your withdrawal is still lawful ;
11.2.5 restrict the processing of your personal data where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending, or you require us to keep it in connection with legal proceedings; and
11.2.6 to object to the processing of your personal data, where we rely on legitimate business interests as a lawful reason for the processing of your data. You also have the right to object where we are processing your personal data for direct marketing purposes. We have a duty to investigate the matter within a reasonable time and act where it is deemed necessary. Except for the purposes for which we are sure we can continue to process your personal data; we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.
11.3 The way we process your personal data and the lawful basis on which we rely to process it may affect the extent to which these rights apply. If you would like to exercise any of these rights, please address them in writing to the DPM.
11.4 We may need to request specific information from you to help us to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
11.5 You have the right to complain to a supervisory body if you are concerned about the way we have processed your personal data. In the UK this is the ICO – www.ico.org.uk.
11.6 Although you have the right to complain to the ICO, we encourage you to contact us first with a view to letting us help in resolving any queries or questions.
12.1 If you have any questions about any matter relating to data protection or the personal data and/or special category personal data that that we process about you, please contact the DPM.
APPENDIX 1 RETENTION DATA CATEGORY RETENTION PERIOD REASON DISPOSAL
|
DATA CATEGORY |
RETENTION PERIOD |
REASON |
DISPOSAL |
|
Interview records of candidates |
6 months |
To defend against potential legal claims |
Shredding of all hard copies and permanent deletion of all electronic copies which are stored in an organised system |
|
Job applications and CV’s |
Following an unsuccessful application and where you specifically consent to us holding your details for longer for the purpose of contacting you if any similar jobs / roles become available from time to time we will hold your details for up to 24 months.
Where we have obtained renewed consent from yourselves at the 24 month mark, we may hold this data for longer. |
To inform you of future opportunities |
Shredding of all hard copies and permanent deletion of all electronic copies which are stored in an organised system |