Candidate Privacy Notice
1. Background to this Candidate Privacy Notice
This Candidate Privacy Notice (this “Privacy Notice”) applies to personal data related to your application and/or consideration for potential employment with the Company as referred to below. This Privacy Notice applies to all candidates that are considered for employment in any of our European offices.
The Company processes personal data when considering you for employment, and will do so in accordance with all applicable laws, as further described in this Privacy Notice.
This Privacy Notice applies to personal data that the Company, like any employer, needs to run our business, recruit a high quality workforce, and manage our relationship with you, at all stages of the recruitment process. We process personal information for a range of purposes associated with the recruitment process, including in relation to your application, assessments, pre-employment screening, reference checking, your right to work permissions, and communicating with you.
This Privacy Notice sets out:
Why we collect your personal information;
What information is collected;
How it is processed;
Who receives it; and
Your legal rights to control its use.
If you become an employee, then we will inform you of other data processing necessary in connection with your employment.
The Company also processes personal data in connection with its online advertising business, however that activity is not covered by this Privacy Notice. If you have questions regarding how the Company processes data for that purpose, or want to manage your choices in relation to that type of data, please consult the Company’s specific Privacy Notice for that activity here: https://www.captifytechnologies.com/privacy-notice/
2. Data Controller and Data Protection Officer Details
The entity that decides the purposes for which and ways in which personal data relating to you is processed is:
Captify Technologies Limited, (registered in England with company number 07620174) if your employment will be with the UK office;
Captify Technologies Sarl, (registered in Paris with SIRET 81799374400033) if your employment will be with the French office;
Captify Technologies S.r.l., (registered in Milan with Codice fiscale 12435680967) if your employment will be with the Italy office
Captify Technologies Pty Ltd, (registered in Sydney with ABN 32 645 671 629) if your employment will be with the Australia office
Captify Technologies S.L., (registered in Madrid with CIF B88405956) if your employment will be with the Spain office
Captify Technologies Inc., (registered in New York with TIN 37-1800636) if your employment will be with the US office
Some of these entities may make decisions in relation to data processing jointly with Captify Technologies Limited; and if you will work in any other place where we have operations then, unless otherwise specified, the relevant data controller will be Captify Technologies Limited (as applicable, referred to as the “Company”)
For any personal data-related issues you can contact:
(a) The Captify People Team; or
(b) The Company’s Data Protection Officer at:
5 Langley Street
London, WC2H 9JA, UK
3. What types of personal data does the Company process?
This Privacy Notice covers the Company’s processing of “personal data”, which is defined as follows:
‘Personal data’ - means any information relating to you (or any other identified or identifiable person), which may include name, address, telephone numbers (including mobile phone number), education, experience, memberships and qualifications, skills and attributes, interests, household, tax and social security information, and details of or any change in your personal circumstances which affects, or may affect, your tax status or right to work in the role for which you are applying.
'Special categories of personal data' - means personal data that is regarded as sensitive and subject to additional protections under applicable laws. This data will only be processed for certain narrowly defined purposes as set out in this Privacy Notice or applicable laws (please see section 3k).
The personal data the Company may hold includes:
a) Your CV, application letter, tests, samples, or application forms, information given in interviews
c) Records relating to your employment history, such as training, appraisals, other performance measures and, where appropriate, disciplinary and grievance records;
d) Correspondence with or about you, for example offer letters;
e) Data regarding past, desired and possible compensation: basic salary, benefits, bonuses, etc.;
f) Contact and emergency contact details;
h) Criminal convictions data: the Company does not currently process such data and would do so only where this is expressly permitted or required by the law and in accordance with all applicable restrictions
i) CCTV Images and video footage of what takes place at our office locations (e.g. when you attend an interview), at all times of day, in real time.
We operate CCTV cameras within our office in clearly signed locations. Footage is recorded for the purposes of maintaining the health and safety of employees and preventing crime and theft of property.
CCTV footage from these cameras is generally held for a maximum of 30 days from the time of recording. The data is stored by Nest (a division of Google LLC https://nest.com/uk/privacy/) who may be contacted at email@example.com
Access to footage is administered by the Company’s CFO, Head of People and CTO (in the case of technical fix requirements);
j) Nationality / visa / right to work permit information; (e.g. passport, driving licence, National Insurance numbers);
k) Special categories of personal data:
Health: Where necessary, we may keep personal data relating to your health or medical conditions. This personal data will be used in order to comply with our health and safety and occupational health obligations – to consider how your health might affect your ability to do your job and whether any adjustments to your tasks or the workplace might be appropriate.
Diversity and inclusivity: With your consent, we may use racial and ethnic origin, religious beliefs, and sexual orientation data in order to plan initiatives in relation to diversity and inclusivity and improving equality of opportunity and treatment among our employees, and to review their impact. This will always be done using aggregated data which cannot be used to identify any one individual. You are under no obligation to provide this data and you can change your mind at any time.
The only other times we would process special categories of personal data are where this information is:
Necessary for compliance with laws or carrying out employment-related rights and obligations;
Required to protect your health or safety in an emergency;
Something that you have made publicly available.
l) Feedback on our selection and recruitment processes.
Much of the personal data we hold will have been provided by you, but some may come from other external sources, such as referees, personal recommendations, or from publicly available sources such as business or employment social networking services or job boards.
4. Why does the Company need to collect and process this personal data?
The Company keeps and processes personal data relating to you in order to:
Manage and process your application and for general recruitment and selection purposes, on the basis that it is necessary for the legitimate interests of the Company to do so;
Comply with applicable laws or regulations;
In the case of special categories of information (as per the detail in section 3) where we have obtained your explicit consent or where permitted by applicable laws.
5. Who receives your personal data?
We may transfer personal data about you to other Company offices for purposes connected with your application or recruitment process, or the management of the Company’s business.
We may use third party data processors (such as recruitment or personnel agencies, HR management software tools, recruitment sites, or, where necessary and permitted, background checking services) to manage personal data in connection with our recruitment processes, who may be located within the UK or EU or elsewhere. Whenever your data is transferred to other places, we have in place safeguards to ensure the security of your data which may include:
Where this is required by law, we will provide a copy of the safeguards applicable to your personal data, if we receive a valid request.
At our discretion, we may disclose CCTV footage and/or personal data in response to valid requests from the police and other statutory law enforcement agencies or if otherwise required by law.
6. How long do we keep your personal data?
Your personal data will be stored only for as long as it is needed for the purpose for which it was obtained.
In any event, we need to keep data as follows:
a) For job applicants and candidates: not more than 18 months after the role has been filled (unless you ask or authorise us to keep it for longer)
b) For CCTV footage, no longer than 30 days.
7. What are your rights?
You have a number of rights with regard to your personal data, i.e.:
To ask for access to it;
To ask for errors in it to be corrected;
To ask for it to be erased (the “right to be forgotten”);
If not erased (e.g. if it is required to be kept for legal reasons), then to ask us to restrict its processing;
To object to its processing for specific purposes;
To ask for a copy to take (or have us provide) to another data controller. Please note that this would relate only to information provided by you – information the Company has received from others or created internally would not be covered.
We are not usually required to ask for your consent for the processing of personal data, as such processing is necessary for the reasons set out in this Privacy Notice. However, where we do rely on any consent that you have given, then you are always allowed to withdraw your consent at any time (though the processing that took place before withdrawal will still be legal).
In certain circumstances it may not be possible for these rights to be exercised in full or at all as they are closely related to your application or required by applicable employment laws. We will explain any actions we have taken or not taken in relation to any request you make.
We are always available through the contacts in Section 2 above to help resolve any issues or doubts you may have in relation to processing of your personal data. If you believe that your rights have not been respected at any time then you also have a right to complain to the Supervisory Authority in your country (in the UK, the Information Commissioner’s Office – “ICO”; in France, the Commission nationale de l'informatique et des libertés – “CNIL”; in Spain, the Agencia Española de Protección de Datos – “AEPD”) to ask them for a resolution.
8. Consequences of not providing (or updating) data
Other than where we have asked for your consent for data processing, our processing of personal data is necessary for the reasons set out in this Privacy Notice. If you wish to object to processing of personal data relating to you, or require us to delete it, this could lead to us being unable to complete the recruitment process or comply with other legal obligations. If so we will tell you about the potential effects of our not having the proper data in those circumstances.
Last updated: July 2023