Last Updated on Dec 18, 2024
Individual Applicant Privacy Notice
Sensemitter Services Limited ("the Company", “we”, “us”) is committed to protecting the privacy and security of your personal data. This privacy notice applies to job applicants, potential candidates for employment, and potential contractors or consultants (“you”). It explains what personal data we collect, why we collect it, how we use it, and your rights in relation to your data in compliance with EC Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”).
Data Controller Details. The Company is the data controller of your personal data, which means we determine how and why your personal data is used. If you have any questions, please contact our Data Protection Officer at legal@sensemitter.com.
What Information We Collect. We collect and process the following types of information:
- Identification Information: Your full name, address, contact details (email, phone number, ID in messengers), date and place of birth, nationality and residency;
- Professional Information: Details of your qualifications, education, skills, experience, employment history, details of your former employment (including positions held, working locations, working hours, years of relevant work experience, achievements), and compensation;
- Right to Work: Information about your right to work in the relevant country, including visa or permit status, and, as the case may be,
- Special Categories of Personal Data: Information about any disability for which we need to make reasonable adjustments during the recruitment process, and, where permitted, background checks including criminal record. We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing.
We may collect this data from your application, CV, cover letter, interviews, assessments, or from third parties such as recruitment agencies, former employers, and background check providers.
Why We Process Your Data. We process your data for the following reasons:
- Pre-contractual Steps: To assess your suitability for engagement with us and take steps at your request prior to entering into a contract. This includes making decisions about who to offer employment to, making decisions about remuneration and other benefits, assessing training, sponsorship and/or relocation needs and opportunities;
- Legal Obligations: To comply with legal requirements, such as verifying your right to work with us in a certain jurisdiction;
- Legitimate Interests: To verify your information, to manage the recruitment process, keep records, and respond to legal claims.
How We Use Your Data. We use your data to:
- Evaluate your suitability for a particular present or future role(s) in the Company;
- Verify your information and background, if applicable;
- Comply with legal requirements;
- Communicate with you during or after the recruitment process.
In addition to using applicant data for the position for which you have applied, the Company may retain and use your data to consider you for other positions or opportunities. Unless required for tax or other legal purposes, your data will be retained for a maximum of 3 (three) months (or less where required by law). If you do not want to be considered for other positions or would like to have your applicant data erased, please contact Legal Department at legal@sensemitter.com.
Data Sharing. Your data may be shared internally with relevant personnel of the Company involved in the recruitment process, such as HR and hiring managers. If you are offered and accept employment or engagement with us, the information collected during the application and recruitment process will become part of your employment record and will be shared with internal employees in IT, Legal, Compliance, etc of the Company and, as the case may be, with HR and hiring managers of the Company’s affiliates (such as, for example, Wayvee https://wayvee.com/). Your information will only be shared if it is necessary to do so and will be limited to what is necessary.
How We Protect Your Data. We have implemented policies and technical controls to protect your data against unauthorized access, accidental loss, destruction, or disclosure. Third-party providers handling your data are also required to comply with GDPR requirements and secure your data.
Data Retention. If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable opportunities, we will keep your data for 1 (one) month once the recruitment exercise ends. If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for contractors and employees, which will be provided to you.
Your Rights Under GDPR, you have rights regarding your personal data:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice;
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request;
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it;
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it;
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes;
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests;
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
To exercise any of these rights, please contact our Data Protection Officer at legal@sensemitter.com.
Data Transfers Outside the EEA. If we transfer your data outside the EEA, we will ensure that appropriate safeguards are in place to protect your data, such as standard contractual clauses approved by the European Commission.
Automated Decision-Making. We do not make decisions solely based on automated processing that have a significant impact on you.
Complaints. If you believe we have not complied with your data protection rights, you may contact the Commissioner for Personal Data Protection in Cyprus via https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/page1i_en/page1i_en?opendocument.
Confidentiality. During the hiring process or thereafter, the Company may share certain information with you about its internal processes, procedures, customers, approaches, business indicators, affairs, and other similar information disclosed in any medium or format, including orally. This information may be designated as confidential or, given the circumstances of its disclosure, should reasonably be considered confidential. If your application is unsuccessful and there will be no further cooperation between us, you agree to treat all Company’s confidential information as confidential for a period of one year following the last interview between you and the Company and not to disclose it to any third party.
Changes to this Privacy Notice. We may update this Privacy Notice periodically. We will inform you of any material changes.