Data Privacy and Transfer
Applicant Data Privacy Notice (UK) (the “Privacy Notice”)
Purpose of personal data collection
If you apply for a role with The Pew Trusts, or its subsidiary (the Pew Research Center) (“Pew”), the personal information you provide to Pew as a result of your application will be held and processed by or on behalf of Pew as needed solely for purposes related to the assessment of your suitability for employment or in contracting with you for employment. Pew will be the data controller under the Data Protection Laws (as defined below). During the recruiting process, we will use the information you provide on your application form or otherwise, to assist in our selection and recruitment process and to assess your suitability for employment. As part of assessing your application for employment, we may seek further or confirmatory information about you from you, your referees and/or your former employers, to the extent permitted by law. We may also be provided with further or confirmatory information about you from third parties who we engage to assist us in the recruitment process, such as skills testers or background check providers. If you provide us with personal data about members of your family and/or dependents or beneficiaries (for example, for emergency contact or benefits administration purposes), it is your responsibility to inform them of their rights with respect to such information. You are also responsible for obtaining the explicit consent of these individuals (unless you can provide such consent on their behalf) to the processing (including transfer) of that personal data for the purposes set out in this Privacy Notice.
Categories of personal data
The majority of the information you provide on the application form will amount to “personal data” as this term is defined under the EU General Data Protection Regulations (the “GDPR”) and the Data Protection Act, its national equivalent (together, the “Data Protection Laws”), and some of this data may also qualify as “special categories of data” under the Data Protection Laws.
The personal data we collect and process includes the following categories (where applicable to your application for employment and Pew’s consideration of your application, up to and including the process of entering into a contract of employment):
- Pre-employment background information, such as candidate details, status, ranking, email address, address, current employer, job history, work and corporate title, education, qualifications, references, copies of right to work documentation, criminal record checks, desired function and work location, licenses, certificates, work experience, resume information, notice period and other information included in a CV or cover letter or as part of the application process.
- Contact information, such as full name, including title, name at birth and preferred name, and phone number.
- Qualified HR data, such as nationality, passport number and issue information, residency status, date of birth, birth city and country, gender, marital status, relationship information, primary language, language skills, visa type and information (work permit/business/etc.), home address and home telephone number, and personal mobile phone number.
- Health information, such as health and disability information.
By choosing to submit your application, you acknowledge and agree to Pew and its subsidiary processing data relating to you in connection with your application for legal, personnel, administrative and management purposes and in particular you acknowledge and agree to the processing of any sensitive or special categories of personal data relating to you, including, as appropriate:
- information about your physical or mental health or condition in order to take decisions as to your fitness for work and/or any adjustments that may need to be taken to enable you to work in a particular role, and to comply with internal recruitment practices and procedures and any legal requirements;
- your racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation;
- information relating to any criminal proceedings in which you have been involved for insurance purposes and in order to comply with internal recruitment practices and procedures, legal requirements and obligations to third parties; and
- any other special categories of personal data to be processed.
Sensitive or special categories of personal data will only be processed where required for the relevant purposes.
Sources of personal data
We may collect personal data from the sources listed below:
- Directly from you, such as through your data input into our website, the application process or via other forms or information you provide to us in connection with your employment or engagement with us (job application, employment contract, benefits application forms, personal details form, internal resume/management profile, emergency contacts, etc.);
- Through your activities in the course of the application process, such as through the interview process; and
- From third parties, including references and other background screening checks, former employers, and employment recruitment agencies, subject to the requirements of applicable law.
Retention of personal data
By choosing to submit this application you also acknowledge and agree to Pew and its subsidiary storing such personal data and special categories of data for no longer than is necessary to carry out the purposes listed in this Privacy Notice or as otherwise required by law. Your personal data will be stored in various secure databases containing applicant and employee data to be accessed for the purposes of considering your application for employment, in the event of future vacant positions, in the administration of your employment and/or as required in connection with any legal proceedings. Pew will retain your personal data for seven years following the end of your employment or other business relationship.
Transfer of Personal Data
Your personal data will be disclosed within Pew and its subsidiary outside the European Economic Area only to those individuals who need access to your Personal Data for the purpose of conducting pre-employment background checks and / or during the recruitment process or where required or permitted by applicable law.
By submitting this application you further acknowledge and agree to the transfer of such personal data and sensitive personal data to iCIMS and Pew and its subsidiary outside the European Economic Area in order to host your profile data and further Pew and its subsidiary’s business interests, respectively, even where the country or territory in question does not provide a level of data protection equivalent to that of your home country. In particular, you acknowledge and agree to the transfer of your personal data and sensitive personal data to iCIMS and Pew and its subsidiary’s offices in the USA. All of Pew and its subsidiary’s recruitment decisions are made in the USA, which is the purpose of the overseas transfer to which you acknowledge and agree by submitting this application or any other personal data relating to your employment at Pew or its subsidiary.
In addition, Pew may need to transfer personal data and sensitive personal data to third party providers solely for purposes related to the assessment of your suitability for employment or in contracting with you for employment, respectively, even where the country or territory in which the third party is located does not provide a level of data protection equivalent to that of your home country. The types of third parties to whom Pew may need to transfer personal data include, but is not limited to: background check providers; payroll providers; HR information system providers; pension, insurance and benefits administrators; IT service providers; auditors; travel providers; legal advisors and/or other professional advisors. Pew will take appropriate steps to make sure that such recipients of your personal data act in accordance with applicable law. To the extent Pew transfers personal data outside the European Economic Area, Pew will provide, and will take appropriate steps to ensure that such recipients provide, an adequate level of protection of your personal data, including appropriate technical and organisational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law.
The Company uses standard contractual clauses in the form approved by the European Commission (http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915) (http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087). Copies of the contractual clauses may be obtained by sending your request to the Company at the contact details listed below under paragraph 11.
Pew and its subsidiary will process your personal data and special categories of data for its internal records and for the purposes for which you have provided it as set forth above. Your privacy is paramount to us. This data will be processed in a fair and lawful manner. Pew and its subsidiary will not share your personal data or sensitive personal data with third parties except as set out above or as necessary to carry out our business or as required by law or other legal processes. Your personal data and any sensitive personal data will be retained only for as long as necessary to fulfill the purposes for which you have provided it as set forth above, or as required by law.
Under the Data Protection Laws, you have certain rights to: (i) access your personal data (subject to applicable laws); (ii) request correction of your personal data that is inaccurate; and (iii) in certain circumstances, you also may have the right to object for legitimate reasons to the processing of your personal data in accordance with the Data Protection Laws.
This policy is owned and administered by the Senior Vice President, General Counsel and Corporate Secretary, who may be contacted by emailing email@example.com or by calling (202) 552-2000. If you have any questions or concerns about this Policy, any concerns about your information being processed as outlined above, if you require access to your personal data held by Pew, or if you would like to correct your personal data, please contact the organisation using the contact information provided above. If you have any questions or comments relating to this policy, please contact us before submitting your application. In addition, you have the right to complain to the supervisory authority about Pew’s processing of your personal data. The applicable supervisory authority of the UK is the Information Commissioner’s Office.
We do not collect any additional information about you other than that outlined above. Under no circumstances will the information you provide be used for marketing purposes.