Recruitment data policy
TimeXtender is a software company with headquarters in Denmark and in the United States, but acting all around the globe. As data is one of our main subjects, we take good care of protecting yours.
As part of any recruitment process, we collect and process personal data related to job applicants. We are committed to exercising transparency regarding how we collect and use that data to meet our data protection obligations. We are directing you to this policy, because you are probably applying to become a part of TimeXtender. The purpose of our data policy is to make you aware of how and why your personal data will be used and how long it will be retained for. It provides you with important information that must be provided under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018.
Data Protection Principles
TimeXtender will comply with data protection laws and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have informed you about and limited to only those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the mentioned
- Kept secure.
What information does TimeXtender collect?
We collect, store and use a range of information about you, relating to your application.
- The information you have provided in any curriculum vitae and cover letter.
- The information you have provided on our application form, including your name, address and contact details – email address and telephone number.
- Details of your qualifications, skills, experiences and employment history.
- Information about your current level of employment.
- Any information that you provide us during an interview, including interview notes, the records of any tests or assessments and reference and background
- Information providing you with the outcome of an interview selection process, including correspondence and any feedback given.
We may also collect, store and use the following category of more sensitive personal information
- Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process.
We may also collect personal data about you from third parties, such as:
- recruitment agencies
- references supplied by former employers
- information from employment background check providers
- information from criminal records checks
We may seek information from third parties and will inform you if we are do so.
Why does TimeXtender process personal data?
We need to process data to decide whether you meet the minimum requirements to be shortlisted for a role and whether your application meets the requirements to invite you to an interview. If we decide to call you for an interview, we will use the information you provide us during the interview to decide whether to offer you the role. We will take up references and carry out appropriate checks. We also need to process your data to enter into a contract with you, if you are the successful candidate.
In some cases, we need to process data to ensure that it is complying with its legal obligations. 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 us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond and defend against legal claims.
Where we rely on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of applicants and has concluded that they are not.
How does TimeXtender process special categories of personal data?
We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability, for example whether adjustments need to be made during a test or interview. This is to carry out its obligations and exercise specific rights in relation to employment.
Where we process other special categories of data, such as information about ethnic origin, sexual orientation, religion or belief, marital status, gender re-assignment and age status this is for equal opportunities monitoring purposes.
Data that we use for equality purposes is anonymized for any publication purposes and is collected with the express consent of candidates, which can be withdrawn at any time. Applicants are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so. This data is kept in a secure online location with limited access only by specific individuals involved in the recruitment process.
Recruitment processes will occasionally use automated decision-making for example to confirm that you meet the minimum statutory requirements for a job. Where automated decision-making prevents you continuing with your application you may request a review of the decision in accordance with your statutory rights under the relevant data protection legislation by contacting us before the published closing date.
Who has access to data?
With the exception of equality information, your information will be shared internally for the purposes of the recruitment exercise on a ‘need to know’ basis – including with members of the People and recruitment team, interviewers involved in the recruitment process, managers in the business area of the vacancy and IT staff – in our legitimate interests of deciding whether to offer you employment and in order to comply with its legal obligations and enter into a contract with you.
In special occasions we will transfer Personal Data to our headquarters in the United States. Special occasions include, for example:
- if we need the expertise from a colleague in the US regarding your application
- if you will be reporting to a US based manager
- if the job application includes a stationary working period in the US
We will only transfer Personal Data from the European Economic Area to the United States in accordance with applicable law.
How does TimeXtender protect data?
We take the security of your 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.
Where we engage third parties to process personal data on its behalf – they do so on the basis of written instructions and for specified purposes – are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
For how long does TimeXtender keep data?
In case of unsuccessful application:
If your application is unsuccessful, your personal data will remain in the recruitment management system for maximum 6 months after the end of the relevant recruitment process. If we need or like to keep the data for longer, we will get in contact with you. At the end of that period or sooner, if you withdraw your consent and we have relied on that consent for lawful processing of your data, your data will be deleted or destroyed. Notes will also be scanned and stored in the recruitment system and deleted alongside the application. Additionally, information relating to the selection process – that is held outside of the recruitment management system – will be destroyed 6 months after completion of the end of the relevant recruitment process.
In case of successful application:
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file, made available to you and retained during your employment. The same process will take place for the panel notes that have been made during the process.
As a data subject, you have a number of rights. You have the right to:
- get information about what personal data we process, how and on what basis.
- access and obtain a copy of your data on request.
- require us to change incorrect or incomplete data.
- require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing for which it was collected.
- require us to delete or stop processing your data if processing is unlawful.
- object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing.
- ask us to restrict the use of data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.
- object if we process your personal data for the purposes of direct marketing.
- transfer your personal data to another controller (excluding paper files).
- not be subjected to automatic profiling (with some exceptions).
- be notified of a data security breach concerning your personal data where this is likely to result in high risk to your rights and freedoms.
- not to consent or to withdraw your consent later, in the case that we request your consent as a lawful ground to process your personal data for a specific purpose.
If you would like to exercise any of these rights or make a subject access request, please email: email@example.com.
If you believe that TimeXtender has not complied with your data protection rights, you can send a complaint to the Data Protection Authority. DPAs provide expert advice on data protection issues and handle complaints lodged against violations of the GDPR. Full contact details can be found below.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us 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 – or provide any reasonable adjustments to the application process.
When you apply, you also provided your consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent please contact firstname.lastname@example.org
Once we have received notification that you have withdrawn your consent, we will no longer process your application and we will dispose your personal data securely.
Link to the relevant extracts from the General Data Protection Regulation (GDPR)