ExpressionEdits Ltd Privacy Notice for applicants
1. Company Information
ExpressionEdits Ltd is a company registered in England and Wales under the number 13517470 and whose registered office is at 3rdFloor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT.
Our Data Protection point of contact is our Chief Operating Officer, Rebecca Godfrey. You can contact Rebecca via email at privacy@expressionedits.com.
2. This Notice
This Applicant Privacy Notice (the “Notice’’) sets out the basis on which ExpressionEdits Ltd and its affiliates (collectively “Company”, “we”, “us” and “our”) will process the Personal Data of job applicants (the “Applicants”, “you”).
Please read this Privacy Notice carefully because it explains important information about the Processing of your Personal Data by us, including your rights with respect to your Personal Data.
ExpressionEdits Ltd is the data controller for the processing of your Personal Data as described in this Notice.
If you have any questions regarding this Notice, you can contact us at privacy@expressionedits.com.
3. What is covered by this Notice
This Notice applies to the processing of Personal Data. For the purpose of this Privacy Notice, “Personal Data” means any information relating to an identified or identifiable person, and “processing” means any operation or set of operations which is performed on that Personal Data.
Within the category of Personal Data, are “special categories of personal data”, which require a greater degree of protection while processing. This includes data on physical and mental health, racial or ethnic origin, political opinions, trade union membership, religious beliefs, sexual life and genetic and biometric data.
4. Personal Data that Company Processes about Applicants
Company may collect the following categories of Personal Data, directly from Applicants:
Contact details: including name, mailing address, e-mail address and phone number;
Information you provide in your CV or on an application form: including, but not limited to, your education, professional and training history, details of any other relevant skills, such as language capability, details of referees;
Any other information you choose to share with Company, including in your CV or cover letter;
As appropriate, copies of certificates, diplomas or other documentation verifying the information you provide to us;
Correspondence and other communications, when we communicate with you via a contact form on our website, email, phone or other means;
Information captured as part of the application process, including interview notes and internal communications; and
Right to work information: information required to confirm your right to work in the country in which you will be employed, including as appropriate your nationality, national identity number and passport details.
We may also collect information from third parties, including:
References, from professional referees on request;
Information provided to us by recruitment agencies or other referring parties; and
Information made publicly available by you via LinkedIn.
To the extent permitted by applicable law, Company may compile Personal Data about an Applicant obtained through a background check.
We also collect, use and share aggregated data such as statistical data.
Personal Data you provide to us on your referees will be Processed by us for the purpose of obtaining an employment reference for you. It is your responsibility to inform your referees about the processing of their Personal Data for these purposes and to confirm that they have given their permission.
If, where we are processing your Personal Data to perform our contract with you, you do not provide the Personal Data, we may not be able to conclude or fulfill such contract.
5. Purpose and Legal Bases for the Data Processing
The Company Processes Applicant Personal Data for the following purposes:
negotiating and communicating with you in relation to your application;
reviewing your suitability for joining Company, seeking references and conducting any appropriate checks;
undertaking efficiency and recruitment efficacy analytics;
workforce planning;
candidate prospecting;
preventing illegal working; and
carrying out equal opportunities monitoring.
We process Applicant Personal Data on the basis of several legal justifications:
For Contractual Purposes: Company and applicants are working together with a view to potentially entering into a contractual relationship. For successful Applicants, Company will make a formal offer of employment that will generally require the preparation of contractual terms.
For our Legitimate Interests: Company has a legitimate interest in hiring people who are suitable to work at Company, communicating with you, workforce planning and improving and monitoring the application process. In such use cases, the privacy risks to the individuals impacted must be sufficiently outweighed by Company’s legitimate business interests.
To Fulfill a Legal Obligation: Certain laws and regulations may require Company to Process the Personal Data of Applicants in order to comply with our legal or regulatory obligations, including checking Applicants have a right to work in the jurisdiction in which they are applying for a position.
Your Consent: To the extent that none of the foregoing legal bases apply, we may ask, in limited circumstances, for your express written consent to Process your Personal Data, including to keep you updated on other positions you may be interested in. You can withdraw your consent at any time and free of charge by contacting our Data Protection point of contact at privacy@expressionedits.com. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
Company may also Process “special categories of personal data” but only where that Processing is required by law or where it is in the public interest (such as data on race or ethnicity for equal opportunity measures or diversity and inclusion initiatives). In limited circumstances Company may seek your explicit consent to process such data. It is not, however, a condition of your contract that you agree to any such request by us.
6. How We Share Your Personal Data
For the purposes set out in Section 5 above, Company may share your Personal Data with other parties.
Affiliates:
Affiliates and subsidiaries of ExpressionEdits, for purposes consistent with this Notice.
Service providers:
Other recipients of your Personal Data include our service providers who perform services on our behalf such as recruitment service providers, IT companies or service providers, cloud processors, security companies and other service providers appointed by Company from time to time.
Controllers:
We may also share your Personal Data with other parties who provide products or services to us, such as our headhunters and banks. These third parties will also be data controllers of your Personal Data, which will be Processed in accordance with the third party’s privacy policy.
Business transaction:
If Company is involved in a merger, acquisition or asset sale, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data may be transferred including as part of any due diligence process.
Legal:
Information including Personal Data may be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce contractual terms, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Company, our employees, a third party, or the public.
7. Your Rights and Choices
Depending on your geographic location and the data privacy laws in your country, state or region, you may have the right to:
access the Personal Data we hold about you;
request we correct any inaccurate Personal Data we hold about you;
request we delete any Personal Data we hold about you;
restrict the processing of Personal Data we hold about you;
object to the processing of Personal Data we hold about you; and/or
receive any Personal Data we hold about you in a structured and commonly used machine readable format or have such Personal Data transmitted to another company.
To exercise any of your rights or choices in connection with your Personal Data, please contact us using the information at the top of this Notice. Please note that we may ask you to verify your identity before responding to such requests. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. Note that applicable laws contain certain exceptions and limitations to each of these rights.
8. International Data Transfers
If you reside in the EEA, Switzerland or UK, your Personal Data may be transferred outside of the EEA, Switzerland or the UK, to countries that may not offer an equivalent level of protection for your Personal Data. Regardless of where your Personal Data is transferred, we shall ensure that relevant safeguards are in place to afford your information adequate protection and we will comply with applicable data protection laws, in particular by relying on an EU or UK adequacy decision, or on contractual protections for the transfer of your Personal Data. Further details regarding the relevant safeguards can be obtained from us on request be contacting us as described at this top of this Notice.
9. Retention of Personal Data
We keep your data as long as necessary to fulfill the purposes described in this Notice, or for so long as we are required to do so by law or in order to comply with a legal obligation.
10. Security of Personal Data
We maintain administrative, technical and physical safeguards designed to protect the Personal Data you provide or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
11. Complaints
If you wish to lodge a complaint about how we process your Personal Data, please contact us at privacy@expressionedits.com. We will endeavor to respond to your complaint as soon as possible. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place. For example, if you are based in the UK, you may choose to lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/.
ExpressionEdits Ltd is registered with the Information Commissioner’s Office under reference number ZB441010.
12. Changes and Updates to this Notice
We may update this Notice from time to time. We advise you to consult this Notice on a regular basis to ensure you stay informed of any such amendments.
If we make material changes, we will let you know via email or a prominent notice on this page, prior to the change becoming effective.
13. Contact Us
ExpressionEdits Ltd is the entity responsible for the processing of your Personal Data and is the data controller in respect of such processing. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Data, please contact us by email at privacy@expressionedits.com.
Text and information below this line should not be included on external facing sites. In its place should be:
POL-006 Privacy Notice (Recruitment)
Version 0
Effective 26 January 2023
Approved by Kärt Tomberg, CEO on 26 January 2023
3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT