Recruitment Privacy Notice

Effective date January 1st, 2020

At DBR Search, we understand that your privacy is important to you. DBR Search and our clients may process your personal data in our capacity as data controllers. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Recruitment Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with our recruiting processes and programs.

 

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment or partnership, and our optional recruiting programs and events. 

As used in this Privacy Notice, “personal data” means information that identifies job applicants and potential candidates for employment with us or our clients, either submitted as part of the online application and/or through alternative channels.

 

We will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail.

By submitting your personal data to us, you acknowledge that:

  • You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.

  • Your personal data may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice.

  • You are not required to provide any requested information to us, but failing to do so may result in not being able to continue your candidacy for the job for which you have applied.

  • All of your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.

  • This Privacy Notice does not form part of any contract of employment offered to candidates hired by DBR Search or our clients.

 

Personal data we collect

The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which the position is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of personal data we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located.

We usually collect personal data directly from you when you apply for a role with us, such as your name, address, contact information, photographs and videos, work and educational history, achievements, and test results. We collect similar personal data about you from third parties, such as your references, prior employers, other candidates with whom you have worked with, and employment background check providers, to the extent this is permitted by applicable law. We may also collect personal data about you online to the extent that you have made this information publicly available. For example, we may find your profile on professional social media websites (such as LinkedIn) and contact you about suitable roles.

 

Sensitive personal data is a subset of personal data and includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, as well as other categories as prescribed by law. We do not seek to obtain and will not collect such data about a candidate unless permitted to do so by applicable laws (e.g., US equal opportunity monitoring).

 

Use of your personal data

We collect and use your personal data for legitimate human resources and business management reasons including:

  • identifying and evaluating candidates for potential employment, as well as for future roles that may become available;

  • recordkeeping in relation to recruiting and hiring;

  • ensuring compliance with legal requirements, including diversity and inclusion requirements and practices;

  • conducting criminal history checks as permitted by applicable law;

  • protecting our legal rights to the extent authorized or permitted by law; or

  • emergency situations where the health or safety of one or more individuals may be endangered.

We may also analyze your personal data or aggregated/pseudonymized data to improve our recruitment and hiring process and augment our ability to attract successful candidates.

 

The legal basis by which we process your personal data

Our processing of your personal data for the purposes mentioned above is based:

  • in part, on our legitimate interest in evaluating your application to manage our relationship with you and to ensure that we recruit the appropriate candidates, and to evaluate and maintain the efficacy of our recruiting process more generally;

  • in part, on our need to perform contractual and precontractual measures in respect of our relationship with you:

  • in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations;

  • In part, on your consent, when we ask you if you wish to be part of our optional recruiting programs.  

 

Data recipients and international data transfers

Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries. Individuals performing administrative functions and IT personnel within our clients organizations may also have a limited access to your personal data to perform their jobs. In some countries, you may have fewer rights under local law than you do in your country of residence, but we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by DBR Search and our clients, including the transfer of your personal data to countries other than the one in which you reside.

We use third party service providers to provide a recruiting software system.  We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data. Where required by law, we put in place legal mechanisms designed to ensure adequate data protection of your personal data in a third country.

Data retention

If you accept an offer of employment by us o one of our clients, any relevant personal data collected during your pre-employment period may become part of your personnel records and will be retained in accordance with specific country requirements. If we do not extend an offer to you you, we may nevertheless continue to retain and use your personal data for a period of time (which may vary depending on the country) for system administration purposes, to consider you for potential future roles, and to perform research. Thereafter, we retain a minimal amount of your personal data to record your recruiting activity with us to enable us to understand whether you have previously applied for a role (or roles) at one of our clients. We may want to remain in contact with you and consider you for future employment opportunities.

 

Your rights

We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this Privacy Notice and applicable law.

 

In accordance with applicable law, you may have;

  • a right to request a copy of the personal data we hold about you and details of how we use that information;

  • a right to amend or rectify your personal data if any of the information held about you is incorrect or out of date;

  • a right of portability of your personal data;

  • a right to erase your personal data, to demand that we cease the processing of your personal data, to restrict the processing of your personal data, and/or to withdraw your consent to the processing of your personal data. This may not apply if there are other legal justifications to continue processing and we may need to retain certain personal data where required or permitted under applicable law, and; 

  • a right to provide us with instructions as to the processing of your personal data in case of death.

 

To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in the Firm’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.

 

Social Media Tools

Our application process allows you to pull relevant information from social media websites (such as LinkedIn, Google Drive and Dropbox) into your application form. If you choose to feed any personal data from such social media tools, it will be used in accordance with this Privacy Notice.

 

Cookies and other tracking technologies

We may use first party and third party cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) to identify you and your interests, to remember your preferences, and to track your use of our websites. We also use Cookies and Other Tracking Technologies to control access to certain content on our websites, to protect the websites, and to process any requests that you make of us.

Some of our online recruiting activities are hosted by third parties. When you access sites operated by these third-parties, they may, consistent with our Cookie Policy, place Cookies or Other Tracking Technologies on your device.