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Privacy Notice for Recruitment

Last updated: April 09, 2024

TWelcome to the recruitment process at SBC Digital. Our Privacy Notice outlines how we handle your Personal Data throughout this process, emphasising our commitment to safeguarding your privacy and ensuring data security.

This Privacy Notice applies to all candidates participating in our recruitment process. If you are successfully hired and become an employee, you will then be subject to our employee policies.

Contact Information
Definitions
Information We Collect
Methods of Collection
Consent for Database Storage
Consent for Recording Sessions
Storage of Personal Data
Sharing of Personal Data
International Data Transfers
Your Data Protection Rights
Updates to this Privacy Policy

SBC Digital is the Data Controller responsible for Processing of your Personal Data. Any references in this document to “we”, “us” or “our” are references to SBC Digital only.

All references to “you” and “your” encompass all individuals who are data subjects, whose Personal Data we collect, hold, and process as a Data Controller.

Contact Information

If you have any questions or need support regarding your data, reach out to us.

Company Name: SBC Digital s.r.o. ("SBC Digital")

Email: contact@sbc-digital.com

Address: 150 00, Czech Republic, Praha, Plzeňská 3350/18, Smíchov

Definitions

“Personal Data” refers to any information relating to an identified or identifiable natural person.

“Data Subject” is an individual who can be identified, directly or indirectly, by reference to Personal Data.

“Processing” encompasses any operation or set of operations performed on Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination.

“Data Controller” is the entity that determines the purposes and means of the Processing of Personal Data.

“Data Processor” is an entity that processes Personal Data on behalf of the controller.

“Privacy Regulations”refer to the laws and regulations governing the collection, processing, and protection of Personal Data.

Information We Collect

Throughout the recruitment process, we collect various types of Personal Data tailored to each stage and the specific requirements of the role you are applying for. As the recruitment process and stages may vary depending on the position, the types of Personal Data collected include, but are not limited to:

Application Submission

  • Contact Information – your name, address, email address, and phone number.
  • Professional Experience – details from your CV, social media profile (e.g. LinkedIn), cover letters, and application forms, providing insight into your work experience. This encompasses dates of employment, job titles, job descriptions, skills, competences, language proficiency, reasons for leaving previous roles, previous salary and benefits information, professional websites/blogs/pages, areas of interest, and notice periods/availability for employment.
  • Portfolio – examples of your work, such as projects, presentations, or creative samples, to evaluate your skills and expertise.
  • Sample Works – specific examples of your work relevant to the position may be requested to gauge your capabilities.
  • Salary or Remuneration Expectations – information regarding your expected salary or remuneration package for the position.
  • Communication Data – details of interactions between you and our recruitment team, including but not limited to emails, phone calls, video conferences, in-person meetings, and any other forms of correspondence exchanged during the recruitment process.
  • Preferences – your preferences regarding data privacy and marketing communications.
  • Additional Documents – any supplementary documents or information provided by you to enhance your application.

Purposes of Processing: Assessing your suitability for employment, evaluating your qualifications for the position applied for, and determining your potential fit within the company.

Legal Basis for Processing: Legitimate interests in assessing candidates' qualifications and suitability for employment.

Interviewing

  • Interview Notes – written summaries capturing key points discussed during interviews, including interview questions, notes, and technical assessment results.
  • Recorded Sessions (if applicable and with consent) – Video or Audio recordings of online video meetings, interviews, or assessments.
  • Feedback – Any feedback you provide regarding your experience with our recruitment process.

Purposes of Processing: Assessing your communication skills, professionalism, and fit within the company.

Legal Basis for Processing: Consent (for interview recordings, if applicable), legitimate interests in assessing candidates' suitability for employment.

Screening and Assessment

  • Right to Work Information – details to assess your eligibility to work in the designated location, including your age, nationality, work permit status, and any necessary documentary evidence, in accordance with local regulations and your explicit consent.
  • Educational Qualifications – degrees obtained, academic transcripts, and educational institutions attended.
  • References and Recommendations – details of professional references provided by you, including their contact information and any letters of recommendation obtained from them.
  • Assessment Results – outcomes of evaluations and tests conducted during the screening process, such as technical tasks and other assessments.

Purposes of Processing: Confirming your eligibility for employment and ensuring compliance with legal obligations; evaluating your qualifications, skills, and experience to determine your suitability for the position.

Legal Basis for Processing: Legitimate interests in assessing candidate qualifications and compliance with legal obligations.

Background Checks

  • Identity Documents – copies of identity documents, as required for verification purposes.
  • Employment Verification – verification of previous employment history.
  • Educational Verification – verification of educational credentials.
  • Criminal history (if applicable) – information obtained through criminal background checks.
  • Credit history (if applicable) – information obtained through credit checks.

Purposes of Processing: Verifying your background, qualifications, and suitability for employment.

Legal Basis for Processing: Compliance with legal obligations, legitimate interests in ensuring the integrity and security of our workforce.

Offer and Onboarding

  • Offer letters – formal offers of employment, including terms and conditions of employment, and your responses.
  • Employment contracts – formal contracts outlining the terms of employment.
  • Onboarding documentation – documents required for the onboarding process, such as tax forms and confidentiality agreements.
  • Support and Accommodation Requests – requests aimed at fostering inclusivity and ensuring compliance with equality legislation.

Purposes of Processing: Facilitating the onboarding process and ensuring compliance with legal requirements.

Legal Basis for Processing: Contractual necessity, compliance with legal obligations.

Methods of Collection

We collect your Personal Data through various means and at different stages of the recruitment process. The methods of collection may include, but are not limited to:

  • Directly from You. We collect Personal Data directly from you when you submit your application for a position with SBC Digital. This includes information provided in your CV, cover letter, portfolio, sample works, and any additional documents or information requested during the application process.
  • Through Our Website or Recruitment Portals. If you apply for a position through our Website or third-party recruitment portals, we may collect Personal Data such as your name, contact information, and employment history through online forms or application portals.
  • Through Correspondence. We may collect Personal Data through correspondence with you, including email communication, telephone conversations, or in-person interviews. This may include information shared during screening interviews, assessment activities, or discussions with recruiters or hiring managers.
  • From References and Third Parties. We may collect Personal Data from references provided by you or obtained through background checks. This may include employment verification, educational verification, and recommendations from previous employers or educational institutions.
  • Through Assessment Activities. If assessment activities are part of the recruitment process, we may collect Personal Data generated from these activities, such as test results, assignment submissions, or assessments of skills and competencies.
  • Recorded Interviews (if applicable). In some cases, interviews may be recorded with your consent. Any Personal Data collected through recorded interviews will be handled in accordance with applicable Privacy Regulations.
  • Referral Program. If you are referred to SBC Digital through our referral program, we may collect Personal Data about you from the referring employee. This may include your name, contact information, and details about your qualifications and experience provided by the referring employee.

As part of our ongoing efforts to facilitate future hiring needs and talent acquisition efforts, we maintain candidate databases where we store personal data of potential candidates.

We obtain explicit consent from candidates before storing their Personal Data in our candidate database. By providing consent to store your Personal Data in our candidate database, you agree to be considered for future job opportunities and similar vacancies that match your qualifications and experience.

Candidates are provided with an easy and accessible opt-out mechanism if they no longer wish to have their Personal Data retained in our candidate database. Opting out does not impact the candidate's eligibility or consideration for current or future job opportunities with our company.

During the recruitment process, we may conduct video or audio recordings of online video meetings, interviews, or assessments. Before recording any session, we will obtain your explicit consent. Your consent allows us to record these sessions for the purpose of evaluating your candidacy for the position applied for and facilitating the recruitment process.

Your participation in recorded sessions is entirely voluntary, and you have the right to refuse consent without any adverse impact on your application. If you provide consent but later wish to withdraw it, you may do so at any time by informing us, and we will cease recording sessions accordingly.

Please note that any recordings made with your consent will be handled in accordance with this Privacy Notice and applicable Privacy Regulations. Recorded sessions will only be used for the intended purposes stated above and will not be shared with third parties without your explicit consent or unless required by law.

Data Retention

We adhere to stringent data retention policies that are periodically reviewed and updated to align with changes in legal requirements and business needs.

Personal Data collected during the recruitment process is retained for the duration of the recruitment process and for a maximum period of 180 days thereafter. However, if candidates provide consent to keep their information in our candidate database for future job opportunities, the data retention periods will be extended accordingly.

We may retain Personal Data for longer periods if required to comply with legal or regulatory obligations, resolve disputes, enforce agreements, or protect our rights.

Once the retention period expires, or if the data is no longer necessary for the purposes for which it was collected, we securely delete or anonymize the information to prevent identification of individuals.

Storage of Personal Data

The Personal Data collected by SBC Digital is processed at the company’s offices in the European Economic Area (EEA). We adhere to stringent security measures to ensure the safe and confidential storage of your Personal Data.

Your Personal Data is stored securely in electronic systems with restricted access controls and industry-standard encryption. Access is limited to authorised personnel for legitimate business purposes. We enforce strong access controls and authentication mechanisms to prevent unauthorised access.

Third-party vendors or service providers must adhere to our high standards of data security and privacy protection when they process Personal Data on our behalf.

Sharing of Personal Data

We may share your Personal Data under the following circumstances:

  • Affiliated Companies.In some cases, we may share your Personal Data with affiliated companies within our corporate group for recruitment purposes. Any such sharing of Personal Data will be subject to the same level of data protection and confidentiality as outlined in this Privacy Notice.
  • Service Providers. We may engage third-party service providers to assist with various aspects of our recruitment process, such as applicant tracking systems, background checks, or assessment tools. These service providers are contractually obligated to process your Personal Data only as instructed by us and in compliance with applicable Privacy Regulations.
  • Business Partners. Your Personal Data may be shared with trusted business partners for collaborative projects, talent acquisition efforts, and data analytics purposes. This sharing enables efficient collaboration, expands the talent pool, and facilitates informed decision-making.
  • Legal Compliance. We may disclose your Personal Data if required by law or in response to valid legal requests, such as court orders, subpoenas, or requests from public authorities. Additionally, we may share your Personal Data if we believe such disclosure is necessary to protect our rights, property, or safety, or those of others.
  • Business Transfers. In the event of a merger, acquisition, or sale of our business, your Personal Data may be transferred as part of the transaction. We take appropriate measures to ensure the confidentiality and security of your Personal Data during such transfers and notify you of any changes to the ownership or control of your Personal Data.
  • Other Disclosures. Your Personal Data may be shared with third parties for purposes not covered by this Privacy Notice if we have obtained your consent to do so. You have the right to withdraw your consent at any time; however, withdrawal may not affect the lawfulness of Processing based on consent before its withdrawal.

Prior to sharing your Personal Data, we ensure that these third parties adhere to stringent data protection standards and implement appropriate security measures.

International Data Transfers

While most of your Personal Data is processed and stored within the EEA, there are instances where we may need to transfer your information to recipients located outside of the EEA. This could be for reasons such as global operations, legal compliance, or contractual necessity.

To ensure your data remains protected, we take appropriate measures, including:

  • Implementing data protection agreements with recipients.
  • Using standard contractual clauses approved by relevant authorities.
  • Relying on other legal mechanisms recognized under applicable Privacy Regulations.
  • Assessing recipients' data protection practices and security measures.

By providing your Personal Data to us, you consent to its transfer as described in this Privacy Notice. No data transfer will occur to any organisation or country unless adequate controls and security measures are established.

Your Data Protection Rights

You have certain rights regarding your Personal Data. These rights include:

  • Right to Access. You have the right to request access to the Personal Data we hold about you. This allows you to receive a copy of the information and understand how we process it.
  • Right to Rectification. If you believe that any of the Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.
  • Right to Erasure. You have the right to request the deletion of your Personal Data in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.
  • Right to Restriction of Processing. You can request that we limit the Processing of your Personal Data in certain situations, such as when you contest the accuracy of the data or when we no longer need it for Processing purposes.
  • Right to Data Portability. You have the right to receive a copy of your Personal Data in a structured, machine-readable format and transmit it to another Data Controller. This right may apply in limited circumstances and is subject to certain conditions.
  • Right to Object. You can object to the Processing of your Personal Data in certain situations, such as when we process it based on our legitimate interests. For example, if you believe that Processing your data for a particular purpose is unnecessary or unjustified, you can object to that processing.
  • Right to Withdraw Consent. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any Processing we conducted prior to your withdrawal.
  • Right to Object to Automated Processing.You have the right not to be subject to a decision based solely on automated Processing of your Personal Data, including profiling, which produces legal or similarly significant effects on you. There may be exceptions or limitations to this right as defined under applicable Privacy Regulations.
  • Right to Complain.If you have any concerns about how we handle your Personal Data or believe that your data protection rights have been infringed, you have the right to lodge a complaint with the relevant data protection authority. If you are a resident in the EEA, you can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

To exercise any of these rights, please contact us at contact@sbc-digital.com. We will respond to your request in accordance with applicable Privacy Regulations.

You have the right to exercise your privacy rights without discrimination and free of charge. However, if your request is clearly unfounded or excessive, a reasonable fee may apply.

Please note that legal obligations or legitimate interests may restrict some requests. If we can't fulfil your request, we'll inform you and provide reasons for any limitations.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our privacy practices or legal requirements. We will notify you of any material changes to this Privacy Notice by posting the updated version on our Website or through other appropriate channels. We encourage you to review this Privacy Notice periodically for the latest information about our privacy practices.

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