Effective: May 1, 2018
By applying for an employment position at Avolution, online or offline, you voluntarily choose to provide Avolution with your personal data and you explicitly consent to the collection, processing and use of the information subject to the guidelines as described herein. We know that you care how we use the information about you and we appreciate your trust in us to do that carefully and sensibly. This Policy outlines how we collect, use and transfer (collectively “process”) the personal data of our candidates (“Personal Data”).
WHO IS THE CONTROLLER?
The controller is the hiring Avolution company; it determines how and why your Personal Data is processed. Our company addresses can be found below at “Questions and Queries.”
PROCESSING OF YOUR PERSONAL DATA
How and why we process your Personal Data?
Avolution will process your Personal Data for job recruiting and placement purposes, including notification of future job opportunities, and, for successful candidates, for employment purposes. You will find details on the Personal Data processed and the purposes for this processing below. Sometimes, these activities are carried out by third parties, including other Avolution affiliates (see “Does Avolution share Personal Data with others?” below).
If provided to us, we process the following categories of Personal Data about you:
- Identification data, including first name and surname;
- Contact information, including home address, phone/mobile/fax number, e-mail address;
- Gender, date of birth, citizenship;
- Data regarding responses to screening questions (where applicable);
- Background and criminal check information (where applicable);
- Previous employment information, including date of hire, job title, department and business unit, work location, work status (full time, part time, contractor), data pertaining to work preferences and abilities;
- Resume, including education, past work experience and references;
- Information on certain health conditions (only where required by law);
- Job interview notes; and
- Assessment results.
Processing of this Personal Data is required to enable Avolution to administer the recruiting process, including the set-up of an electronic job applicant Human Resources (“HR”) file, contacting you about your application or for interviews, reviewing and managing your application, keeping records related to the application, hiring and employment process, organizing interviews, making any verification required or permitted by applicable local law, preparing candidates for employment when a job has been offered and accepted – in short, the complete process necessary for us to enter into a contract with you. In case of legal proceedings, we will need to process your Personal Data to establish, exercise or defend us against the legal claim. We may also share your Personal Data with other Avolution affiliates to consider you for future job openings and will retain your data for a limited period of time beyond an unsuccessful application for this purpose, subject to your rights to object to such use of your Personal Data (see below at “What are my rights under applicable data protection laws”).
WHERE DOES AVOLUTION OBTAIN MY PERSONAL DATA FROM?
Most of the Personal Data we process is obtained from you when you file your application with and submit your resume, CV, compensation requests, transcripts, references and related information to Avolution, but we also obtain Personal Data about you in the course of the application process (for example, during interviews or via job assessments). Other data types may be obtained from third parties, including for example, background and employment check agencies, recruitment agencies and employment references you provide. In the event that Avolution uses an online candidate account system where you elect to use your external social media accounts, such as Facebook, Google+, LinkedIn or Microsoft, to facilitate the set-up of your Avolution candidate online account, you acknowledge that Avolution will be provided with the latest information from your social media accounts. Additional privacy terms of the social media service providers may apply as well.
Voluntary Disclosure. Your provision of Personal Data in connection with recruiting and the application process is entirely voluntary, and you determine the extent of information you provide to Avolution. Please note that if you decide not to provide information, it may affect our ability to consider you for employment. By applying for employment with Avolution, you are authorizing Avolution to obtain reference information such as information about criminal record, educational history, military service, and former employment. You are also giving your consent for all persons you name to Avolution, including your former employers, to provide information concerning you and your former employment to us. Avolution will not be liable to you for reacting upon the reference information.
Reference and Background Checks. Your Personal Data will also be obtained from the successful completion of background checks. The background check may include and Provide Data relating to: verification of education, past employment, criminal background reports, motor vehicle driving records, reference checks, civil suit records, drug test and/or investigations into incidents involving theft, fraud, harassment and workplace violence.
Sensitive Personal Information. Avolution does not request or require sensitive Personal Data concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. If you have a disability and would like Avolution to consider any accommodation, you may provide that information during the recruiting process. As well, in some countries we ask for information such as race or ethnicity for the purpose of monitoring equal opportunity; however, we do not require applicants to provide race or ethnicity information, and if you provide this information it will not be viewable in the hiring or selection process.
To the extent information you provide to us, during the recruiting or application process or otherwise, details of your racial or ethnic origin, political opinions or beliefs, religious beliefs, membership in a trade union or political party, physical or mental health or condition, sexual orientation, commission or alleged commission of an offense or related proceedings, job evaluations or educational records, you expressly authorize Avolution to handle such details as specified in this policy.
DOES AVOLUTION SHARE PERSONAL DATA WITH OTHERS?
Our Affiliate Companies
Avolution is a global company that operates joint-administrative and cross-national by using multiple systems in order to share information about HR for the purposes of a unified recruiting system. Avolution may process the Personal Data manually or automatically by authorized employees of the Avolution affiliates and/or other authorized assigned third parties. Personal Data will only be shared across the Avolution affiliates in certain circumstances where it is lawful to do so, for example with limited members of the HR Department, the Legal Department or the IT department, all of which may be working for different Avolution affiliates. Whenever we need to share your Personal Data, we will only do so on a need-to-know basis and with selected employees for tasks within their job responsibilities. Avolution takes appropriate steps to ensure that such employees are bound by duties of confidentiality with respect to your Personal Data.
We use third party service providers who provide technical and support services in connection with the recruitment, application and employment process. In providing the services, your Personal Data will, where applicable, be processed by the service provider on Avolution’s behalf.
We will confirm for any third party that we use that they can provide sufficient guarantees regarding the confidentiality and security of your Personal Data. We will ensure that any third party complies with our data security standards and international transfer restrictions.
Disclosure to other third parties
Avolution does not sell your Personal Data to third parties. In certain circumstances, we share and/or are obliged to share your Personal Data with third parties outside Avolution, for the purposes described above and in accordance with applicable data protection laws. These parties will act as controllers of your Personal Data in their own right, and they will be responsible for compliance with applicable data protection laws.
These third parties may include:
- Insurance companies;
- Law enforcement personnel; public prosecutors;
- External advisers (such as legal advisers, accountants);
- Payroll and bookkeeping companies;
- Benefits providers;
- Advisers in the event of a corporate transaction such as a merger or sale of assets; and
- Pension companies and trustees.
DOES AVOLUTION TRANSFER PERSONAL DATA TO COUNTRIES OUTSIDE THE EEA?
We also transfer the Personal Data we process to countries outside the European Economic Area (”EEA”), for example, when one of our service providers (including Avolution affiliates) use staff or equipment based outside the EEA. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights.
HOW IS MY PERSONAL DATA SECURED?
We maintain physical, electronic and procedural safeguards to protect the confidentiality, integrity and availability of your Personal Data. We have in particular taken appropriate security measures against unlawful or unauthorized processing of Personal Data, and against the accidental loss of, or damage to, Personal Data.
HOW LONG DOES AVOLUTION STORE MY PERSONAL DATA?
If your application for employment is successful and you commence employment with Avolution, your Personal Data will be transferred to your personnel file and will be processed for employment purposes.
If your application for employment is not successful, we will keep your Personal Data for a period of one year upon notification that your application was not successful for the purposes of (i) contacting you for future job vacancies and (ii) the establishment, exercise or defense of legal claims. To the extent permitted or required by law, Avolution may delete Personal Data at any time; accordingly, you should retain your own copy of any information you submit to us.
WHAT ARE MY RIGHTS UNDER APPLICABLE DATA PROTECTION LAWS?
You have the right to request: access to, correction and/or deletion of your Personal Data at any time during or after the application process, to ask for data portability, as well as – depending on the laws of your country – to define instructions for your Personal Data after your death. You are also entitled to object to the processing of your Personal Data in certain instances. If we process your Personal Data based on your consent, you may withdraw it for the future at any time. For questions and queries please contact us at “Questions and Queries” below.
WHAT ARE MY RESPONSIBILITIES?
You are responsible for the information you provide or make available to Avolution, and by providing it to Avolution in any form, you are certifying that it is honest, truthful, accurate, complete and not misleading in any way. Any omission or misrepresentation of any material fact from any information you provide or make available to Avolution at any time and in any form will be cause for immediate dismissal. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. Further, if you provide any information concerning any other person, such as individuals you provide as references or family member/‘next-of-kin’ contact, you are responsible for providing any notices and obtaining any consents necessary for Avolution to collect and use that information as described in this policy.
QUESTIONS AND QUERIES
If you have any complaints regarding our compliance with this Policy, you should first contact us at firstname.lastname@example.org with a thorough description. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your personal information in accordance with this Policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact the regulatory authorities.
CHANGES TO THIS NOTICE
We may update this Policy from time to time. In the event we make a material change that reduces your rights or Avolution obligations under this Policy, we will use commercially reasonable efforts to provide you with the updated Policy in advance of the change actually taking effect and will post a prominent notice in this section of this Policy notifying users when it is updated. We encourage you to review the content of this Policy regularly.
Last updated: May 1, 2018