Applicant Privacy Notice
Two Circles Limited, Two Circles AG and Two Circles Inc are each a “data controller” in the context of collecting, holding and using personal information about you as an applicant (whether as an employee, worker or contractor) for a job with us. This privacy notice 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 General Data Protection Regulation ((EU) 2016/679) (GDPR).
Data Protection Principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- 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, current and expected remuneration.
- Information obtained from your passport or other identity documents.
- Any information you provide to us during an interview or other method of assessment or any information otherwise voluntarily communicated to us by you during the recruitment process.
- CCTV footage and other information obtained through electronic means such as swipe card records to the extent that your application for work with us requires you to attend any of our offices.
We may also collect, store and use the following types of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Selected recruitment agencies, from which we may collect the same categories of data as set out above (save for CCTV footage and other information obtained through electronic means relating to your attendance at our offices).
- CRI Group, a background check provider, who may perform standard credit, criminal record and previous employer checks should you be applying for certain specialist positions.
- Disclosure and Barring Service in respect of criminal convictions.
- Your named referees.
- Our serviced officer providers from which we may receive CCTV footage and other information obtained through electronic means such as swipe card records to the extent applicable.
- The following data from third parties is from a publicly accessible source: information obtained from public social media profiles or sources.
How we will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the applied work or role.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to process data from applicants to manage the recruitment process, assess your suitability for the applicable job or work and ultimately decide whether to appoint you to the applicable role or work since it would be beneficial to our business to appoint someone to that role or work. We have a legitimate interest in processing personal data as part of the recruitment process and in order to maintain records of such process. We may also need to process data from job applicants to respond to and defend against legal claims or to ensure compliance with legal or regulatory requirements (including checking a successful applicant’s eligibility to work in a particular jurisdiction).
If you fail to provide personal information
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 a credit check or 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
We will use your particularly sensitive personal information in the following ways:
- 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.
- 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.
Information about criminal convictions
We do not envisage that we will process information about criminal convictions.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application: (i) other entities within the Two Circles group; and (ii) our shareholders and/or entities within our holding structure, recruitment agencies, our serviced office providers, the Disclosure and Barring Service in respect of criminal convictions, your referees and CRI Group. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data which you provide directly to Two Circles for their own purposes. We only permit them to process such personal data for specified purposes and in accordance with our instructions and we will only share such information with such third-party service providers to the extent necessary.
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.
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.
How long will you use my information for?
We will retain your personal information for a period of 12 months after we last communicated with you. 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 in accordance with our data retention policy.
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
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- 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.
- 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.
- 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).
- 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.
- 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.
- Request the transfer of your personal information to another party.
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 Commercial Operations Director in writing.
Data Protection Officer
We have appointed a data protection officer 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 protection officer at DPO@twocircles.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.