RLE INTERNATIONAL PRODUCT DEVELOPMENT LTD IS COMMITTED TO PROTECTING THE PRIVACY AND SECURITY OF YOUR PERSONAL INFORMATION.
THIS PRIVACY NOTICE APPLIES TO ALL PROSPECTIVE EMPLOYEES, WORKERS AND CONTRACTORS APPLYING TO WORK WITH US IN ACCORDANCE WITH THE GENERAL DATA PROTECTION REGULATION ((EU) 2016/679) (GDPR).
- WHAT IS THE PURPOSE OF THIS DOCUMENT?
RLE Product International Development Ltd is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying to work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the GDPR.
- DATA PROTECTION PRINCIPLES
2.1. We will comply with data protection law and principles, which means that your data will be:
2.1.1. Used lawfully, fairly and in a transparent way;
2.1.2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
2.1.3. Relevant to the purposes we have told you about and limited only to those purposes;
2.1.4. Accurate and kept up to date;
2.1.5. Kept only as long as necessary for the purposes we have told you about;
2.1.6. Kept securely.
- THE KIND OF INFORMATION WE HOLD ABOUT YOU
3.1. In connection with your application to work with us, we will collect, store, and use the following categories of personal information about you:
3.1.1. The information you have provided in your curriculum vitae (CV) and covering letter;
3.1.2. The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications;
3.1.3. Any information you provide to us during an interview.
3.2. We may also collect, store and use the following "Special Categories" of more sensitive personal information:
3.2.1. Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
3.2.2. Information about your health, including any medical condition, health and sickness records;
3.2.3. Information about criminal convictions and offences.
- HOW IS YOUR PERSONAL INFORMATION COLLECTED?
4.1. We collect personal information about candidates from the following sources:
4.1.1. You, the candidate.
4.1.2. Any recruitment agency who we have referred to in our initial correspondence (Recruitment Agency), from which we collect the following categories of data: Personal contact details such as name, title, address, telephone numbers, and personal email address; date of birth; right to work documentation; any information provided in your CV and given to the Recruitment Agency as part of your application to work with us;
4.1.3. Your named referees, from whom we collect the following categories of data:
4.1.3.1. Date commenced and ceased employment.
- HOW WE WILL USE INFORMATION ABOUT YOU
5.1. We will use the personal information we collect about you to: 5.1.1. Assess your skills, qualifications, and suitability for the role;
5.1.2. Communicate with you about the recruitment process;
5.1.3. Keep records related to our hiring processes;
5.1.4. Comply with legal or regulatory requirements.
5.2. It is in our legitimate interests to use this information to decide whether to appoint you to the role. We also need to process your personal information to decide whether to enter into a contract of employment with you.
5.3. Having received your CV and covering letter, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.
5.4. If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
- HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
6.1. Where it has been necessary for us to collect sensitive personal information from you, we will use it in the following ways:
6.1.1. We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview;
6.1.2. We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
- AUTOMATED DECISION-MAKING
7.1. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
7.1.1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
7.1.2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
7.1.3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
7.2. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
- DATA SHARING
8.1. We will only share your personal information with the following third parties for the purposes of processing your application:
8.1.1. Other companies, which are part of our group of companies including:
8.1.1.1. RLE International GmbH;
8.1.1.2. RLE International Iberia S.L.U;
8.1.1.3. RLE International USA Inc;
8.1.1.4. RLE India Private Limited;
8.1.1.5. RLE International China Inc;
8.1.1.6. RLE International Australia;
together the Group Companies.
8.1.2. Where the role applied for is specific to a project we are working on with a third party, we will share your personal information with that third party.
8.2. All third-parties and other entities in the Group Companies are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow third-parties to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
8.3. RLE International USA Inc, RLE India Private Limited, RLE International China Inc and RLE International Australia operate in countries where an adequacy decision has not been made by the European Commission. This means that those countries are not deemed to have data protection laws that provide an adequate level of protection to protect as individual’s personal information.
8.4. Please note if it is necessary for a particular role that your personal information:
8.4.1. is sent to one of the Group Companies listed at clause 8.3;
8.4.2. is sent to a third party in accordance with clause 8.1.2 and that third party operates outside of the EEA in a country where an adequacy decision has not been made by the European Commission; we will request your explicit consent to do so.
8.5. Please note where your consent is refused under clause 8.4, this may mean we are unable to continue to process you application.
- DATA SECURITY
9.1. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
9.2. 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.
- DATA RETENTION
10.1. We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to role. 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. After this period, we will securely destroy your personal information.
10.2. If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
- RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
11.1. Under certain circumstances, in connection with your personal information, by law you have the right to:
11.1.1. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
11.1.2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
11.1.3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
11.1.4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
11.1.5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
11.1.6. Request the transfer of your personal information to another party.
11.2. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Lorraine Jones in writing.
11.3. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
11.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- DATA PRIVACY MANAGER
We have appointed Lorraine Jones as our data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager [Lorraine.jones@rle.co.uk]. You have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues.