1. INTRODUCTION

HDI Global SE – UK and HDI Global SE – Ireland (together the "Company") is committed to protecting the personal data of its job applicants. This Notice sets out important information about how the Company collects and uses your personal data during the course of the application and recruitment process.

You should read this Notice carefully and raise any questions you may have with the HR Manager.

2. SCOPE

This Notice applies to job applicants to the Company. In connection with the recruitment process, the relevant data controller is the UK branch of HDI Global SE and we can be contacted at 10 Fenchurch Street, London EC3M 3BE. In Ireland the relevant data controller is HDI Global SE – Ireland and can be contacted at Hampton House, 27 Mount Street Lower Dublin 2.

3. WHAT PERSONAL DATA DO WE COLLECT?

Personal data means information which identifies you and relates to you as an individual. As your prospective employer, the Company will collect, use and store your personal data for a wide variety of reasons in connection with the application and recruitment process. We have set out below the main categories of candidate personal data which we process in connection with our recruitment activities on a day to day basis:

personal contact information (including your name, home address, personal telephone number(s) and personal e-mail address)
work history and other relevant experience including information contained in CV, cover letter or job application form
education information including degrees awarded, transcripts and other information provided in support of the job application
compensation history
information collected during phone screenings and interviews
details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits
reference information and information received from background checks (where applicable) including information provided by third parties
information related to previous applications to us or previous employment history with us
documents evidencing your right to work (including information about your immigration status where relevant)
date of birth
gender
information gathered through the Company's monitoring of its IT systems, building access records and CCTV recording in relation to your communications with us and attendance at our premises

The majority of the personal data to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory personal data may affect our ability to accomplish the purposes stated in this Notice, including considering your suitability for employment and/or entering into an employment contract with you.

The list set out above is not exhaustive, and there may be other personal data which the Company collects, stores and uses in the context of the application and recruitment process. The Company will update this Notice from time to time to reflect any notable changes in the categories of personal data which it processes.

The majority of the personal data which we process will be collected directly from you. However, your personal data may also be provided to us by third parties, such as recruitment agencies, former employers, official bodies and/or medical professionals.

4. REFERENCING AND VETTING

As part of our referencing and vetting procedures, we will contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties will include:

former employers in order to verify your previous employment history; and
universities and/or other establishments for higher education that you attended in order to verify your education history.

Our background checking is conducted by a third party (currently Sterling Talent Solutions) on our behalf and we have put in place appropriate safeguards to protect your personal data which is processed in this context.

We will only seek this information in relation to successful candidates that have accepted a conditional offer of employment with us and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.

5. HOW DO WE USE YOUR PERSONAL DATA?

The Company uses your personal data for a variety of purposes in order to take steps necessary to enter into an employment contract with you, to comply with legal obligations or otherwise in pursuit of its legitimate business interests. We have set out below the main purposes for which candidate personal data is processed:

to identify and evaluate job applicants, including assessing skills, qualifications and experience
verifying candidate information and carrying out employment, background and reference checks, where applicable and in order to prevent fraud
communicating with you about the recruitment process and your application
to comply with our legal, regulatory, or other corporate governance requirements
for the purposes of conducting data analytics to review and better understand the operation of our recruitment processes

In addition to using your personal data to consider you for the role you applied for, we will retain and process your personal data to inform you about and to consider you for other roles that may be appropriate for you. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform the HR Manager.

Again, this list is not exhaustive and the Company may undertake additional processing of personal data in line with the purposes set out above. The Company will update this Notice from time to time to reflect any notable changes in the purposes for which its processes your personal data.

6. WHAT SPECIAL CATEGORIES OF PERSONAL DATA DO WE PROCESS?

Certain categories of data are considered "special categories of personal data" and are subject to additional safeguards. The Company limits the special categories of personal data which it processes as follows:

Health Information

We will process information about a candidate's physical or mental health in compliance with our obligations in connection with employment, in particular:

we may process information about an individual candidate's physical or mental health to comply with our obligations to make reasonable adjustments for disabled employees as part of the recruitment process; and
as part of the induction programme for successful candidates we will seek information in order that we can take account of any medical issues relating to a new employee, including our obligation to make reasonable adjustments in the workplace.

We will always treat information about health as confidential and it will only be shared internally or with third parties where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.

If a candidate is successful, any health information processed as part of the recruitment process that is relevant to the Company's compliance with its obligations in connection with employment will be retained and processed in accordance with the Employee Privacy Notice.

If a candidate is unsuccessful, any health information obtained as part of recruitment process will be deleted with the rest of the candidate's personal data within 15 months of the rejection of the application.

Criminal Record Information

Given the nature of our business, we ask employees to disclose their criminal record history and we carry out criminal record checks as part of our background vetting process and in compliance with our obligations in connection with employment. In particular we conduct a 'basic' criminal record check for employees recruited to perform roles in our claims or underwriting functions, in line with our regulatory obligations and the particular risks associated with these functions. We engage a third party to carry out these checks on behalf of the Company (currently Sterling Talent Solutions ).

We will always treat criminal record history as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.

Criminal record information will typically be retained for a maximum of 6 months from the conduct of the check, although the outcome of any check will remain on the employee's personnel record and will be retained and processed in accordance with the Employee Privacy Notice.

7. WHEN DO WE SHARE CANDIDATE PERSONAL DATA?

The Company will share candidate personal data with other parties only in limited circumstances in order to take steps necessary to enter into the employment contract or where necessary to comply with a legal obligation, or otherwise in pursuit of its legitimate business interests as follows:

recruitment agencies
background vetting specialists
occupational health providers
HMRC, the Revenue Commissioners and/or any other applicable government body
the Central Bank of Ireland
accountants, lawyers and other professional advisers

Wherever possible, the candidate personal data is shared under the terms of a written agreement between the Company and the third party which includes appropriate security measures to protect the personal data in line with this Notice and our obligations. The third parties are permitted to use the personal data only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.

8. FOR HOW LONG WILL MY PERSONAL DATA BE RETAINED?

The Company's policy is to retain personal data only for as long as needed to fulfil the purpose(s) for which it was collected, or otherwise as required under applicable laws and regulations. Under some circumstances we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.

For unsuccessful candidates:

We will typically retain personal data collected during the recruitment process for a maximum period of 15 months from the end of the process subject to any exceptional circumstances and/or to comply with particular laws or regulations.
We may retain select data relating to particular candidates on file for a longer period than 15 months and no more than 24 months in order to follow up with the candidates in relation to future vacancies; if you do not wish for your personal data to be maintained on file for this purpose, please inform the HR Manager.

If you are offered and accept employment with us, the personal data we collect during the application and recruitment process will become part of your employment record and we may use it in connection with your employment in accordance with the Employee Privacy Notice.

9. WHAT ARE MY RIGHTS IN RELATION TO MY PERSONAL DATA?

The Company will always seek to process your personal data in accordance with its obligations and your rights.

You will not be subject to hiring decisions based solely on automated data processing without your prior consent.

In certain circumstances, you have the right to seek the erasure or correction of your personal data, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal data. You also have the right to request the transfer of your personal data to another party in a commonly used format. If you have any questions about these rights, please contact the HR Manager.

You have a separate right of access to your personal data processed by the Company. You may be asked for information to confirm your identity and/or to assist the Company to locate the data you are seeking as part of the Company's response to your request. If you wish to exercise your right of access you should set out your request in writing to the HR Manager.

Finally, you have the right to raise any concerns about how your personal data is being processed in the UK with the Information Commissioner's Office (ICO) by going to the ICO's website: https://ico.org.uk/concerns/ or contacting the ICO on 0303 123 1113 or casework@ico.org, and in Ireland with the Data Protection Commissioner's Office (DPC) by going to the DPC's website https://www.dataprotection.ie/docs/Home/4.htm or by contacting the DPC on 1890 252 231 or info@dataprotection.ie

10. WHERE CAN I GET FURTHER INFORMATION?

If you would like further information about the matters set out in this Notice, please contact the HR Manager.