Effective date: January 1, 2020
Crisp Inc respects your privacy and we are committed to protecting your personal data. Crisp is a personal data controller. This means that we are responsible for deciding how we hold and use personal data about you. This notice is aimed at informing you of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR) and the local data protection law.
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.
- Maintained only for as long as necessary for the purposes we have told you about, i.e. in relation to the recruitment exercise.
- Kept securely and protected against unauthorized or unlawful processing and against loss or destruction using appropriate technical and organisational measures.
The Types of Personal Information We May Collect About You
Personal data means any information about an individual from which that person can be identified. Personal data does not include anonymous data. The categories of personal data we may collect and hold about you may include:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
- CV’s or cover letters or any other supplementary document included as part of the application process where requested or not;
- Information regarding your work history, qualifications, professional memberships, education, experience, or employment references;
- Video recordings such as those that may be submitted as part of the recruitment process (in response to specific screening questions);
- Photographs if included on CVs or otherwise on supplementary document submitted as part of the recruitment process; and
- The results of any personality profiling assessment that we may carry out as part of the recruitment process.
We may also collect, store and use the following special categories of more sensitive personal data, which could include:
- Information about whether or not you have a disability for which we need to make reasonable adjustments as part of the recruitment process; and
- Information about criminal convictions and offenses (where the nature of the job requires this).
More information about how we treat special categories of personal data is set out below.
How Is Your Personal Data Collected
We collect personal data about candidates from the following sources:
- You, the candidate.
- Your named referees, from whom we collect the following categories of data: full name, periods of previous employment, performance during previous employment.
- From publicly accessible sources, such as Linkedin, etc.,where we collect your full name, email, work history, and other data included on your profile.
How We Will Use Data About You
We will use the personal data 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.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint a suitable candidate to that role.
We also need to process your personal data to decide whether to enter into a contract with you.
Having received your CV and covering letter and the results from any tests you took, we will then process that data to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is suitable to invite you for an interview. If we decide to call you for an interview, we will use the data you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we may then take up references and/or any other check before confirming your appointment.
If You Fail To Provide Personal Data
If you fail to provide personal data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application further. For example, if we require 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 Data
We will use your sensitive personal data only in so far as we are permitted by Law to do so:
- We will use data about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
- We will use data about your nationality or ethnicity, to assess whether a work permit and a visa will be necessary for the role.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the People Team, relevant hiring managers and interviewers involved in the recruitment process, and IT staff if access to the data is necessary for the performance of their roles.
Crisp will only share your data with third parties for the purposes of assessing your application for employment. This will be with authorized third parties that have been engaged by Crisp such as our applicant tracking system. If you are successful in your application and we make an offer of employment, we may ask for your nominated referees and contact them in order to obtain references for you and we will use your name within that correspondence, and we may contact the Disclosure and Barring Service to undertake necessary criminal records checks (if required for the nature of the role).
Your data may be transferred outside the European Economic Area (EEA) with hiring managers or those participating in recruitment and selection processes as part of the recruitment process.
However, to ensure that your personal information does receive an adequate level of protection we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU laws on data protection.
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. 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 specific instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our website privacy notice.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will retain your personal data for a period of 3 years after your last application date [if you are unsuccessful we shall retain your personal data for 6 months or for a period of 3 years upon your explicit consent]. We retain your personal data 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. We further retain such personal data in case a similar role becomes vacant for which you will be a fitting candidate. Please ensure that your data is kept up to date at all times by logging into the online system. After this period, we will securely destroy your personal data in accordance with our data retention policy.
Rights Of Access, Correction, Erasure, And Restriction
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data 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 data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
Address Data Protection Queries
If you would like to exercise any of these rights, please contact us at firstname.lastname@example.org
If you believe that the data controller has not complied with your data protection rights, you can complain to the Information Commissioner. Contact details for the ICO can be found at https://ico.org.uk/ .
A list of National Data Protection Authorities in the European Economic Area can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm