Purpose and Scope
This Notice provides a comprehensive overview of the practices of Entrust Datacard Corporation and its affiliates (together EDC) with respect to the collection, use, and disclosure of Personal Information from job applicants for recruitment purposes.
Entrust Datacard collects and processes Personal Information from a job applicant to manage the recruitment process (“Recruitment Information”). Entrust Datacard is committed to being transparent about how it collects and uses that Recruitment Information and to meeting its data protection obligations in accordance with fair information practices and applicable data privacy laws.
Personal Information means any information relating to an identified or identifiable natural person. This information includes name, identification number, location data, and online identifier, among other information. Special categories of Recruitment Information (also known as Sensitive Personal Information) means Personal Information related to: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life or sexual orientation, genetic data, and biometric data.
Who is the Data Controller?
For European countries, to identify the EDC entity responsible as data controller of your Recruitment Information, see below table.
|Datacard Limited / Nu-Type Limited||Forum 3, Solent Business Park, Whiteley, Hampshire, PO15 7FH|
|Entrust Europe Limited||Unit 4 Napier Court, First Floor, Napier Road, Reading, Berkshire, RG1 8BW|
|Germany **||Entrust Datacard Deutschland GmbH||Niederkasseler Lohweg 191, D-40547 Düsseldorf, Germany|
|France||Datacard, S.A.S||ZAC des Chatelliers, 200 rue Leonard de Vinci, 45404 Fleury les Aubrais Cedex, France|
|Spain||Datacard Ibėrica, S.L||Parque Empresarial La Finca, Po. Club Deportivo 1, Bloque 3, Bajo, 28223 Pozuelo de Alarcón, Madrid, Spain|
** The legal basis to process personal data is in section 26 of the German Data Protection Law, this is in connection with GDPR
For outside of Europe, you may obtain this information by contacting your local Recruitment team, or the Chief Legal and Compliance Officer at Privacy@entrustdatacard.com
What Recruitment Information does Entrust Datacard collect?
We collect a range of information about you. This includes:
Dependant on local laws, we may also collect, and process the following “special categories” of Sensitive Personal Information:
Entrust Datacard may collect this Recruitment Information in a variety of ways: data might be contained in application forms, CVs or resumes, or obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
Entrust Datacard may also collect Recruitment Information about you from third parties such as through references supplied by former employers, from employment background check providers, and from criminal records checks, where relevant and local laws apply. We will seek Recruitment Information from third parties only once a job offer to you has been made and we will inform you that we are doing so.
Why does Entrust Datacard collect Recruitment Information? How is Recruitment Information Used?
Entrust Datacard needs to process Recruitment Information to take steps prior to entering into an employment contract with you. We may also need to process your Recruitment Information to enter into an employment contract with you.
In some cases, we need to process Recruitment Information to ensure that we are complying with our legal obligations. For example, it is required to check a successful applicant's eligibility to work in the country they are applying to before employment starts.
Entrust Datacard has a legitimate interest in processing Recruitment Information during the recruitment process and needs to keep records of such process. Processing Recruitment Information from job applicants allows Entrust Datacard to manage the recruitment process, assess and confirm a candidate's suitability for employment, and decide whom to offer a job. We may also need to process Recruitment Information from job applicants to respond to and defend against legal claims.
Entrust Datacard may process Sensitive Personal Information, as defined above, to monitor recruitment statistics. Dependent upon local laws, we may also collect information about applicants’ disabilities to determine whether reasonable adjustments need to be made. Entrust Datacard processes such information to carry out its obligations and exercise specific rights in relation to employment.
Dependant on the role and country you are applying to, we are obliged to seek information about criminal convictions and offenses. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.
Do we share and disclose Recruitment Information?
Your Recruitment Information may be shared internally with other EDC affiliates, including members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy, and IT staff if access to the data is necessary for the performance of their roles. These EDC affiliates are permitted to use Recruitment Information in a manner consistent with this Notice.
Entrust Datacard will not share your Recruitment Information with third parties (service providers), unless your application for employment is successful and we make you an offer of employment. Entrust Datacard will then share your Recruitment Information with former employers to obtain references for you, employment background check providers, and criminal records checks providers, where relevant and local laws apply.
How does Entrust Datacard protect Recruitment Information?
Entrust Datacard takes the security of your Recruitment Information seriously. We have internal policies and controls in place to ensure that your Recruitment Information is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Furthermore, we use appropriate technical, organizational and administrative security measures to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction designed to provide a level of security appropriate to the risk of processing your Recruitment Information
For how long does Entrust Datacard keep Recruitment Information?
If your application for employment is unsuccessful, we will hold your Recruitment Information on file after the end of the relevant recruitment process.
For European countries, to identify how long we keep this information, see below table.
|United Kingdom||6 months|
At the end of the above mentioned period, or once you withdraw your consent, your data is deleted or destroyed.
For outside of Europe, this information is retained after the relevant recruitment process in order to build up a talent database for potential future recruitment activities. We will retain your information on our recruitment database unless you withdraw your consent, in which case your data will be deleted or destroyed.
If your application for employment is successful, Recruitment Information gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in an employee privacy notice.
International Data Transfers
Once collected or received, EDC may transfer your Recruitment Information to countries other than the one in which your Recruitment Information was collected. This is necessary in order to consider entering into an employment relationship with you as our organizational structures and management teams are designed across a matrix of offices in a number of countries around the globe. Certain privacy and data protection laws require data controllers to put in place safeguards to protect the Recruitment Information being transferred across borders. To comply with this requirement, EDC has put in place agreements that include the standard contractual clauses recommended by the European Commission to provide adequate safeguards for Recruitment Information.
For questions about safeguards, please contact EDC’s Chief Legal and Compliance Office at Privacy@entrustdatacard.com
What rights do you have with respect to your Recruitment Information?
Subject to the privacy and data protection laws applicable to you, you may have rights in relation to Personal Information we hold about you.
In particular, if European data protection law applies, you will have the following rights:
You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Other jurisdictions may have similar rights.
To exercise your rights, please contact EDC’s Chief Legal and Compliance Officer at Privacy@entrustdatacard.com
What if you do not provide Recruitment Information?
You are under no statutory or contractual obligation to provide Recruitment Information to Entrust Datacard during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Who Can You Contact?
If you have any questions or concerns about this Notice, please feel free to contact EDC’s Chief Legal and Compliance Officer at Privacy@entrustdatacard.com