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This notice explains:
• What personal data we collect during our entire job application, recruitment and onboarding process and why we collect it; and
• How we use that personal data.
This Notice applies to the processing of your personal data by Brainrocket Limited (“We, Us”, “Our”) in the context of a job application to the Company. Please read this alongside our website Privacy Policy.
This Notice also applies to:
• The processing of your personal data in connection to our communication with you;
• The processing of any of your queries;
• The assessment of your job applications recruitment and candidacy;
• The process of onboarding you as a Company employee;
• The Company's compliance with legal requirements we are subject to as an employer;
• Any other relationship with you that is not covered by a separate privacy Notice.
We may process several categories of personal data needed for activities related to the application and recruitment process. These categories may include, but are not limited to:
• Contact details such as name and surname, phone number, email address, and other contact information.
• Information included in your CV and/or cover letter: such as employment history, academic background, skills and experience, languages spoken and written, recommendations and referees and any other information you provide to us in support of an application and/or application and the recruitment process.
• Details of the type of employment you are or may be looking for, current/desired salary and any other terms relating to compensation and benefits packages, right to work in the country where the role you applied to is based and immigration status, information about citizenship and/or nationality, willingness to relocate, and/or other job preferences.
• Information related to assessing your suitability such as information given in interviews, test results undertaken during the recruitment process, and polygraph test results if applicable.
• National Identifiers such as ID card or passport copy.
• Criminal record checks if required by the law.
• General communications.
• Information from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g your LinkedIn profile).
• Technical data on how you interact with our recruitment tools and services including IP address and cookies.
Additionally, during the onboarding stage, your health or medical information may be requested if required by the law or for immigration purposes.
• Assessing your skills, qualifications and interests against our career opportunities.
• Verifying your information and carrying out reference checks and/or conducting background checks where applicable.
• Communications with you about the recruitment process and/or your application(s), including informing you of other relevant opportunities in our company.
• Assisting you with obtaining an immigration visa or work permit where applicable.
• Complying with applicable laws, regulations, legal processes or enforceable government requests.
• Perform our recruitment process.
1. Directly from you: We may receive your personal data directly from you when applying to a position with us.
2. From a third-party: We may also collect your information from recruitment agencies, employee referral programs, educational institutions, professional networking sites such as LinkedIn and Indeed, and other public channels.
3. Automatically collected data: We may automatically collect some data such as your IP address and cookie information when you visit our applicant website or tools.
We only process personal data when we have defined a relevant purpose and a legal ground for the processing. Our lawful grounds are the following:
Purposes of processing
Categories of data
Lawful ground
Evaluate your application and suitability for a role
Contact information
Information included in your CV and/or cover letter
General communications
Information related to assessing your suitability for the role
Concent
Contact you about your application and recruitment process
Contact details
Consent
Evaluate referred candidates
Contact details
Information provided by your referrer
Legitimate interest
Manage, defend, and resolve legal disputes, including any litigation, arbitration, or legal proceedings.
Details relevant to the dispute
Legitimate interest
Ensuring compliance with industry standards and safeguard company operations
Background checks and criminal records where applicable
Legitimate interest
Preparing the employment agreement
Contact details
Identification documents
Compensation and payment or benefit related information
Processing is necessary to take steps prior to entering into a contract
Immigration and onboarding process
Information about right to work and immigration statusNational Identifiers and other information required for relocation process
Processing is necessary to take steps prior to entering into a contract
Respond to and manage requests from data subjects regarding their personal data
All relevant personal data
Compliance with a legal obligation
Verify identity and right to work
National identifiers
Compliance with a legal obligation
Personal data may be shared with, or accessed by, the following categories of recipients, though this list is not exhaustive:
1. Service Providers: We may also use service providers acting on our behalf to perform some of the services described above including but not limited to the purposes of verification/background checks. Some service providers also provide us with services to store and manage applications, schedule interviews, and perform technical assessments of applications. Some of our service providers include BambooHR, GreenHouse ATS, Hogan Assessment, Video interview tools, and HackerRank.
2. Regulatory Authorities: We may also disclose your personal data to regulatory authorities, public agencies, law enforcement and so on for the purpose of complying with applicable laws and regulations, or in response to legal process.
3. Affiliates and business partners: Your personal data may be shared with our affiliates, companies within our group, and business partners, in relation to the purposes described above. Internally: We may share your personal data internally across different teams taking part in your recruitment process. If you have been referred to us by an employee, with your consent, we may inform that employee about the progress of your application and let them know the outcome of the process.
4. Recruitment agencies: We may inform them about the status of your application if your profile was originally provided by them.
5. Corporate Transactions: Your personal data may be disclosed or transferred to relevant third parties in the event of, or as part of the due diligence for, any proposed or actual reorganization, sale, merger, consolidation, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including in connection to bankruptcy or similar proceeding). If a corporate transaction occurs, we will provide notification of any changes to the control of your information, as well as choices you may have.
Your personal data shall not be kept for longer than is necessary for the recruitment process as follows:
• If you are not selected for the position, we will store your personal data for 1 year. This allows us to consider you for future opportunities that may align with your qualifications.
• If we conclude an employment agreement with you, then we will store the personal data collected during the recruitment process for at least the duration of the employment relationship.
How We Protect Your Personal Data
We protect your personal data using industry-standard security measures, storing it primarily within the EU on encrypted drives or in certified data centers. However, data may be transferred to service providers outside the EEA, with safeguards in place to ensure compliance with EU regulations. Our storage environments meet the ISO/IEC 27001 security standard, and we use secure protocols for data transmission. Access to your data is limited to authorized personnel bound by confidentiality. We retain your data only as long as necessary, considering the purpose and legal requirements. We also have procedures for handling data breaches and will notify you if legally required.
International Transfer Of Your Personal Data
Since we operate globally, it may be required to transfer your personal data to service providers, authorities and affiliates in jurisdictions that are outside of the European Economic Area. The data protection and other laws of these countries may not be as comprehensive as those of the European Union. In these instances and where applicable, we take ongoing measures to ensure that such service providers and affiliates have implemented appropriate safeguards to protect the security of personal data. This includes standard contractual clauses that have been approved by the European Commission or in conducting the transfer subject to an EU Commission adequacy decision. Your personal data will never be shared with third parties for their own marketing purposes (unless you give your explicit consent).
Your Rights
1. Right of access: You can inquire if your personal data is being processed, its purpose, categories, recipients (especially in third countries), retention period, and your rights to rectification, erasure, and restriction.
2. Right to rectification: You can request correction of inaccurate or incomplete data about you.
3. Right to erasure: In certain situations, such as withdrawing consent, you can request the deletion of your personal data.
4. Right to restriction of processing: You can ask to limit the processing of your data under specific circumstances, restricting its use to legal claims or rights.
5. Right to object: You can object to the processing of your data if it is based on legitimate interests, including profiling, unless there are compelling legitimate grounds.
6. Right to data portability: If data processing is based on consent or a contract and is automated, you can receive your data in a machine-readable format and request its transfer to another controller if feasible.
7. Right to complain: You have the right to complain to a supervisory authority in the country you reside or work in. You can find a list of all supervisory authorities in the EU here.
Contact Us
If you wish to exercise your rights or you have any questions regarding this policy, please contact our Data Protection Officer through email: dpo@brainrocket.com.
Updates To This Notice
To keep up with changing legislation, best practices and how we process your personal data, we may update this privacy notice from time to time, without notice. If we make any substantial changes while you are involved in a recruitment process, we will notify you.
V1.0
Effective date: October 2024
