As part of any recruitment process, Know Your Customer Limited (“KYC“) collects and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
What information do we collect?
KYC collects a range of information about candidates, which may include:
- The candidate’s name, address and contact details, including email address and telephone number;
- Details of the candidate’s qualifications, skills, experience and employment history;
- Information about the candidate’s current level of remuneration;
- Whether or not the candidate has a disability for which KYC needs to make reasonable adjustments during the recruitment process; and
- Information about the candidate’s entitlement to work in countries where we have offices.
KYC may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from the candidate’s passport or other identity documents, or collected through interviews or other forms of assessment.
We may also collect personal data about candidates from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to the candidate has been made and will inform the candidate that we are doing so.
Data will be stored in a range of different places, including on the candidate’s application record, in HR management systems and on other IT systems (including email).
Why does KYC process personal data?
We need to process data to take steps at the candidate’s request prior to entering into a contract with the candidate. We may also need to process the candidate’s 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.
KYC has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.
Who has access to data?
The candidate’s 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 not share the candidate’s data with third parties, unless the application for employment is successful and we make the candidate an offer of employment. We will then share the candidate’s data with former employers to obtain references, employment background check providers to obtain necessary background checks.
How does KYC protect data?
We take the security of candidates’ data seriously. We have internal policies and controls in place 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 how long does KYC keep data?
If an application for employment is unsuccessful, we will hold the candidate’s data on file for 6 (six) months after the end of the relevant recruitment process. At the end of that period, or once the candidate withdraw their consent, their data is deleted or destroyed.
If an application for employment is successful, personal data gathered during the recruitment process will be transferred to the candidate’s HR file (electronic based) and retained during their employment.
As a data subject, candidates have a number of rights. They can:
- access and obtain a copy of their data on request;
- require us to change incorrect or incomplete data;
- require us to delete or stop processing their data, for example where the data is no longer necessary for the purposes of processing; and
- object to the processing of their data where KYC is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact our legal team at firstname.lastname@example.org.
What if a candidate does not provide personal data?
Candidates are under no statutory or contractual obligation to provide data to KYC during the recruitment process. However, if they do not provide the information, we may not be able to process an application properly or at all.