Job Applicant Privacy Notice
Data controller: Sunmaster Ltd
Sunmaster Ltd is a member of the Emirates Group. The Emirates Group includes a number of related businesses, including:
- Emirates, whose principal office is at Emirates Group Headquarters, PO Box 686, Dubai, United Arab Emirates. Emirates is a Dubai corporation established by Decree No.2 of 1985 (as amended) of the Government of Dubai, which is primarily focused on airline operations and includes divisions and/or entities such as Emirates Skycargo, Skywards and Business Rewards; and
- dnata, whose principal office is at Emirates Group Headquarters, PO Box 686, Dubai, United Arab Emirates. dnata is a Dubai corporation established by Decree No.1 of 1987 (as amended) of the Government of Dubai, which is primarily focused on ground handling, cargo, catering and travel agency services and includes divisions and/or entities such as dnata Travel, Arabian Adventures and marhaba.
You can find out more about the Emirates Group here.
This Privacy Notice covers the Emirates Group, except where you are notified of another privacy notice or policy by the specific Emirates Group entity who collects your personal information.
Providing your personal information
The Emirates Group entity responsible for your personal information is the Data Controller named at the beginning of this Notice. There may be separate or additional applicable privacy notices made available when your personal information is first collected by that Emirates Group entity for other purposes, for example, where you purchase an Emirates product or service from us.
As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. Emirates is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the Emirates Group collect?
We collect a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process; and
- information about your entitlement to work in the UK.
We may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
We may also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does the Emirates Group process personal data?
The organisation needs to process data to take steps with your consent prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts.
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
We may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. The organisation processes such information to carry out its obligations and exercise specific rights in relation to employment.
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment where a role requires a high degree of trust and integrity and so we would like to ask you to seek a basic disclosure of your criminal records history.
The organisation processes information about an individual’s criminal convictions in accordance with its policy on processing special categories of personal data. In particular, data collected during recruitment is held securely and accessed by, and disclosed to, individuals only for the purposes of completing the recruitment process. Inappropriate access or disclosure of employee data constitutes a data breach and should be reported in accordance with the organisation’s data protection policy immediately. It may also constitute a disciplinary offence, which will be dealt with under this disciplinary procedure.
Once an individual is recruited, information about his/her criminal record gathered in the course of the vetting process will not be transferred to his/her personnel file. If your application is unsuccessful, the organisation may keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
We will only share your data with third parties as described in this Notice. If your application for employment is successful and the relevant Emirates Group entity makes you an offer of employment, the organisation may then share your relevant and necessary data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and in some cases the Disclosure and Barring Service to obtain necessary criminal records checks.
Transferring Personal Information Outside the European Economic Area
Your data may be transferred outside the European Economic Area (EEA) to process your application if the Director of your division is based outside of the UK, for example, in the United Arab Emirates, in order to select the right candidate for the job.
Countries outside the EEA are subject to different standards of data protection than the UK.
We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, and we only transfer personal information to another country where:
- we are satisfied that adequate levels of protection are in place to protect your information; and
- the transfers are fully managed to protect your privacy rights and interests and are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.
To this end:
- we ensure transfers within the Emirates Group will be covered by an agreement entered into by members of the Emirates Group (an intra‑group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within the Emirates Group;
In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions.
You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above.
How does the Emirates Group protect data?
We take the security of your data seriously. We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal information that you share with us and to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For example, the measures we take include:
- placing confidentiality requirements on our staff members and service providers;
- destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected; and
- following security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it; and
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
For how long does the organisation keep data?
If your application for employment is unsuccessful, the organisation will hold your data on file for 6 months after the end of the relevant recruitment process. We retain your personal information 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. [If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 6 months for consideration for future employment opportunities. At the end of that period [or once you withdraw your consent], your data is deleted or destroyed in accordance with our data retention policy.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the organisation to change incorrect or incomplete data;
- require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
- Request the transfer of your personal information to another party.
If you would like to exercise any of these rights, please contact [Anna Ricketts, Head of People Resourcing – firstname.lastname@example.org
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Recruitment processes are not based solely on automated decision-making.