SaltPay Recruitment Privacy Notice
last updated: January 12, 2023
This Recruitment Notice (“Notice”) describes how your SaltPay entity collects, uses, discloses, transfers, stores, retains, or otherwise processes your information when you apply to work for us.
For the purpose of this Notice, SaltPay is the data controller unless otherwise specified. The SaltPay entity responsible for the processing of your personal data may depend on your location and the role you applied to.
When you apply to work for us, we collect and process the following categories of personal data:
- contact details such us name, address, e-mail address, telephone number;
- CV related information such as professional experience, professional references, academic records, licences and awards, trade union memberships, languages, and any other data provided by you in the application;
- employment terms such as working patterns, salary expectations, disability and right to work.
This data is collected either i) directly from you or ii) from recruitment agencies and similar organisations we cooperate with.
2. Lawful bases for processing your data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we are about to enter into an employment contract with you;
- 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;
- where we need to comply with a legal or regulatory obligation that we are subject to; and
- where you have provided your consent to us.
3. Purposes for processing your personal data
We have set out below, a description of all the purposes for which we will process your personal data:
- reaching out to you about possible recruitment opportunities (if your details were referred to us by an external entity/person or a current employee of SaltPay)
- administrating our recruitment process including scheduling assessments and interviews
- contacting you to update on your application status
- monitoring diversity and equality of opportunity
- deciding on whether we will extend an offer to you
- entering into a contract (if an offer is made and accepted)
4. Disclosures of your personal data
Apart from SaltPay’s Hiring and People team, your personal data may also be shared with:
- the required internal teams and the staff involved in the recruitment process
- the third-party recruitment agencies and platforms used by SaltPay such as Greenhouse, CodeSubmit, etc.
- regulatory entities in a course of an investigation/formal request.
As SaltPay is a global entity, it may be necessary to transfer your personal data outside the UK/EEA. When we do that, we take reasonable steps to ensure that your personal data is kept secure, including where relevant, signing contractual terms with the receiving party outside the UK or EEA, such as the Standard Contractual Clauses approved by the EU Commission or issued by the UK Information Commissioner’s Office (as applicable) or any other approved mechanisms that may become available to us in the future.
5. Data retention
We keep your personal data for no longer than necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting or reporting requirements. Retention times can vary depending on the applicable local laws, the nature and the amount of personal data and the potential harm to the individuals.
In case you were unsuccessful to the role you applied to, we will retain your CV for 12 months for future job openings.
You can always ask us to delete you CV from our databases by e-mailing our privacy team at email@example.com.
6. Data Security
SaltPay has in place appropriate technical and organisational measures to keep your personal data secure and prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, access to your personal data is limited to those who have a business need to know. They only process your personal data on our instructions, and they are subject to a duty of confidentiality.
7. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected;
- request erasure of your personal data. This enables you to ask us to delete or remove your personal data;
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party);
- request restriction of processing of your personal data;
- request the transfer of your personal data to you or to a third party.;
- withdraw consent at any time where we are relying on consent to process your personal Data; and
- request not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
If you wish to exercise any of the above rights, please contact us at firstname.lastname@example.org. No fee is usually required to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond, in cases of legitimate requests, is one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. Changes to this Notice
SaltPay reserves the right to change, modify or amend this Notice at any time to reflect changes to the way it processes your personal data or any legal updates.
If you have any questions or concerns in relation to this Notice or you would like to exercise your rights as stated in section 7, please contact out Data Privacy team by e-mail at email@example.com.