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RECRUITMENT PRIVACY POLICY

Welcome to Trouva's Recruitment Privacy Policy, last updated on May 25, 2018

What does this Recruitment Privacy Policy Cover?

StreetHub Ltd, an English limited company trading under the name “Trouva” (“Trouva” or “we\") operates in the UK, which has laws in place governing the collection, use, transfer and disclosure of the personal data of individuals, including applicants and candidates for jobs (“Applicants\"). We take our obligations under these laws very seriously and are committed to protecting the privacy of all individuals whose personal data we process.

The purpose of this Recruitment Privacy Notice (“Notice”) is to give Applicants information about:

  • what personal data we collect;
  • how we collect, use and disclose that data and the legal grounds for us doing this; and
  • their rights in respect of their personal data.

We are the Controller of Applicants’ Personal Data and we are responsible for how this personal data is processed. Should you have any questions about the policy and how your personal data is managed in this context, please get in touch by emailing our People Partner at people@trouva.com.

This Notice does not form part of your application or any future contract of employment and may be updated at any time. We will provide you with a revised Notice if we make any substantial updates. It is important you read this Notice, so that you are aware of how and why we are using your personal data.

Information We Collect About Prospective Applicants

Before, during and after their application to Trouva, we may collect and process information about Applicants. We refer to such information in this Notice as “Personal Data”. We collect the following Personal Data:

  • Personal Details: Name, home contact details (email, phone numbers, physical address) languages(s) spoken, gender, date of birth, national insurance number, disability status, emergency contact information and photograph;

  • Documentation Required under Immigration Laws: Citizenship and passport data, details of residency or work permit;

  • Talent Management Information: Details contained in letters of application and resume/CV (previous employment background, education history, professional qualifications and memberships, language and other relevant skills, certification, certification expiration dates), information necessary to complete a background check, information relating to references such as referees’ names and contact details, details on performance management ratings, development programs planned and attended, e-learning programs, performance and development reviews, willingness to relocate, driver���������s licence information, and information used to populate employee biographies;

  • Any other information you provide to us: such as current salary, desired salary, employment preferences; and

  • Special Categories of Personal Data: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person’s sex life or sexual orientation, and criminal conviction data.

We ask that you avoid submitting Special Categories of Personal Data, unless such information is legally required and/or Trouva requests you to submit such information.

Any information you submit to us must be true, complete and not misleading. Submitting inaccurate, incomplete or misleading information may lead to a rejection of your application during the recruitment process or disciplinary action including immediate termination of your employment. In addition, it is your responsibility to ensure that the information you submit does not violate any third party’s rights.

If you provide us with personal data or other information of a referee or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

Sources of Personal Data

We collect Personal Data from the following sources:

  • Applicants: in person, online, by telephone, or in written correspondence and forms;

  • Third-Party websites: where you can apply for jobs at Trouva (as well as professional networking sites such as LinkedIn);

  • Previous employers and other referees: in the form of employment references;

  • Background and credit check vendors: as part of the recruitment process; and

  • Employment agencies and recruiters.

How we use and disclose Personal Data

Legal Basis for Processing

We will only use Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • where it is necessary in order to take steps at your request prior to entering into an employment contract;

  • where it is necessary to comply with a legal obligation (including, in respect of Special Categories of Personal Data, obligations under employment law) on us; and

  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    For example, Trouva has a legitimate interest in conducting certain background checks on Applicants to ensure that it is offering employment to those individuals whom it considers are most likely to be successful when working for Trouva.

We may also use your Personal Data in the following situations, which are likely to be rare:

  • where it is necessary to protect your (or someone else's) vital interests (and, in the case of Special Categories of Personal Data, where you are incapable of consenting);

  • where it is necessary for us to defend, prosecute or make a claim against you, us or a third party; and

  • in the case of Special Categories of Personal Data, where you have made the information public.

In particular, we may use your Special Categories of Personal Data, such as health/medical information, in order to accommodate a disability or illness during the recruitment process, your diversity-related Personal Data (such as race or ethnicity) in order to comply with legal obligations relating to diversity and anti-discrimination, and your criminal conviction data only where it is appropriate (given the role for which you are applying) and we are legally able to do so.

Purposes of Processing

We process Personal Data for the following purposes:

  • Managing Workforce: Managing recruitment and assessing your suitability, capabilities and qualifications for a job with us, approaching you for a role we think is directly relevant to you, processing your application and performing background checks if we offer you a job, such as credit checks and checks to prevent fraud and money laundering;

  • Communications: Facilitating communication with you regarding your application and to keep you updated with relevant job opportunities at Trouva (unless and until you unsubscribe from such communications);

  • Taking legal action: Pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures; and

  • Compliance: Complying with legal (including, in respect of Special Categories of Personal Data, obligations under employment law) and other requirements, such as record-keeping and reporting obligations, anti-discrimination legislation, conducting audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process (such as court orders).

There may be more than one purpose that justifies the use of your Personal Data in any particular circumstance. If you wish to know the particular legal basis on which we rely in respect of a particular purpose for which we are processing your Personal Data (see subsection below), please contact our People Partner by emailing people@trouva.com.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. If you fail to provide certain Personal Data when requested, we may not be able to review your application, or we may be prevented from complying with our legal obligations.

Disclosures to third parties

We share Personal Data with the following unaffiliated third parties:

  • Service Providers: Companies that provide products and services to Trouva such as human resources services, IT systems suppliers and support and background check providers, recruiters and headhunters, and hosting service providers;

  • Previous Employers: Your previous employers in order to perform suitable reference checks; and

  • Public and Governmental Authorities: Entities that regulate or have jurisdiction over Trouva such as regulatory authorities, public bodies, and judicial bodies, including to meet national security or law enforcement requirements.

Transfer of Personal Data

We may share your Personal Data with certain external third parties who are based outside the European Economic Area (“Europe”). Any processing of your Personal Data by these parties will involve an export of your Personal Data outside of Europe. We endeavor to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Data Security

Trouva will take appropriate measures to protect Personal Data that are consistent with applicable privacy and data security laws and regulations, including requiring service providers to use appropriate measures to protect the confidentiality and security of Personal Data.

Access to Personal Data within Trouva will be limited to those who have a need to know the information for the purposes described above, and may include Trouva’s Founders and personnel in Business Operations. Such personnel will generally have access to Applicants’ business contact information such as name, desired position, telephone number, postal address and email address.

Trouva has put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach of your Personal Data where we are legally required to do so.

Data Retention

Trouva’s retention periods for Personal Data are based on business needs and legal requirements. We retain Personal Data for as long as is necessary for the processing purpose(s) for which the information was collected, as set out in this Notice, and any other permissible, related purposes. For example, we may retain certain information to comply with regulatory requirements regarding the retention of such data, or in the event a litigation hold is imposed. When Personal Data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

Data Accuracy

Trouva will take reasonable steps to ensure that the Personal Data processed is reliable for its intended use and is accurate and complete for carrying out the purposes described in this Notice.

Automated Decisions

Trouva does not envisage that you will be subject to decisions that will have a significant impact on you based solely on automated decision-making. Trouva will notify you in writing if this position changes.

Your Rights

You have the right, in certain circumstances, to object to the processing of your Personal Data. You can exercise this right by contacting please contact our People Partner by emailing people@trouva.com

You also have the right, in certain circumstances, to access your Personal Data, to correct inaccurate Personal Data, to have your Personal Data erased, to restrict the processing of your Personal Data, to receive the Personal Data you have provided to Trouva in a structured, commonly used and machine-readable format for onward transmission, and to object to automated decision-making.

If you wish to exercise any of these rights, please contact please contact our People Partner by emailing people@trouva.com Please note that certain Personal Data may be exempt from such access, correction, erasure, restriction and portability requests in accordance with applicable data protection laws or other laws and regulations.

You also can file a complaint with your local data protection supervisory authority. Please contact please contact our People Partner by emailing people@trouva.com for details of the relevant authority.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

Your Obligations

You should keep your Personal Data up to date and inform us of any significant changes to your Personal Data.

Questions or Complaints

Please contact please contact our People Partner by emailing people@trouva.com with any questions or complaints regarding this Notice or Trouva’s privacy practices. Please provide enough information to identify you, including proof of your identity and address.