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Recruitment Privacy Notice

  • What is this notice?

This is the ‘Recruitment Privacy Notice’ of SYKES’ companies in Europe Middle East and Africa.  This notice applies to individuals applying to work with us in Europe Middle East and Africa, including prospective employees, workers and contractors.

We are a data ‘controller’, which means we are responsible for deciding how we hold and use your personal information.  This notice explains how and why we will collect and use your personal information in the context of the recruitment process and your rights in relation to your personal information. We may amend this notice at any time.

  • Data protection queries

If you have any questions about this privacy notice or how we handle your personal information please contact the relevant Data Protection Officer.

Germany – https://www.sykes.com/germany/en/imprint

Denmark, Finland, Norway and Sweden – dataprotection.northern@sykes.com

Egypt, Hungary, Netherlands, Romania and United Kingdom – dataprotection.gemea@sykes.com

  • Your personal information

In this privacy notice, ‘your personal information’ means your personal data i.e. information about you from which you can be identified. The table at section 6 below lists your personal information that we may process.  Your ‘personal information’ does not include data where the identity has been removed (anonymous data).

It is important that your personal information is accurate and up to date. Please inform us if your personal information changes during the recruitment process.

  • Special categories of personal information

‘Special categories of personal information’ means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purpose of uniquely identifying you.

Data marked * in the table at section 6 below falls within these ‘special categories’ or might disclose special categories of personal information.  We must have additional legal grounds for processing special categories of personal information, and these grounds are set out in the table at section 6 below.

  • Where does your personal information come from?

Your personal information will come from you or us, and may also come from the following sources:

  • Recruitment agencies may provide us with the following personal information; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references, immigration status;
  • A contact of yours may provide us with the following personal information as part of our employee referral program; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references;
  • Student organizations (such as AIESEC) may provide us with the following personal information; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references, immigration status;
  • Job boards may provide us with the following personal information; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references, immigration status;
  • In the following countries background check providers may provide us with the following personal information criminal records, media articles, address history, credit history, account payment history and any public records:
    • Cyprus
    • Denmark
    • Egypt
    • Finland
    • Hungary
    • Ireland
    • Italy
    • Netherlands
    • Norway
    • Romania
    • Slovakia
    • Sweden
    • United Kingdom
  • Former employers, whom you have given us permission to contact, may provide us with the following personal information; job titles, salary, work history, evaluations, disciplinary actions, attendance records.

If you would like more information about the source of your personal information please contact the Human Resources or Recruitment Department in the country for which you are applying for a job.

  • Processing your personal information

We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.

In general, we process your personal information for the reasons, and on the legal grounds set out in the following table, and also to:

  • Retain records relating to the recruitment process;
  • Establish, exercise or defend legal claims;
  • Comply with the law [or requirements of a regulator]; and / or
  • Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).
Reason for processing your personal information Legal ground(s) for processing, and legitimate interest (where applicable) Your personal information
Contact you regarding the recruitment process and any offer of work To enter a contract Personal contact details (including name, address, email, telephone number)
Contact you regarding new positions that we may recruit for in the future For our legitimate interests:

  • to source suitable employees, workers and contractors
  • Personal contact details (including name, address, email, telephone number)
  • Your application form, CV and any covering letter or email.
Make a decision about your recruitment or appointment, including assessing your skills, qualifications and suitability for the work To enter a contract

To comply with a legal obligation

For our legitimate interests:

  • to select suitable employees, workers and contractors
  • Your application form, CV, any covering letter or email, and interview notes
  • Results of recruitment tests
If you have accepted an offer of work from us that is subject to such checks:

  • Take up references (from referees whom you have given us permission to contact);
  • Carry out background checks;
  • Confirm your professional memberships, registrations and / or qualifications.
To enter a contract

To comply with a legal obligation

For our legitimate interests:

  • to select suitable employees, workers and contractors
  • References and details of previous employers
  • Professional memberships, registrations and qualifications
  • Correspondence and results regarding background checks.
Determine the terms of any potential contract between you and us To enter a contract

To comply with a legal obligation

Offer letter, and proposed contract between you and us
If you have accepted an offer of work, check you are legally entitled to work in the relevant country To enter a contract

To comply with a legal obligation

Documentation confirming your right to work in the relevant country
Establish whether you can undergo an assessment which forms part of the application process

Consider reasonable adjustments to the recruitment process for disabled applicants

To enter a contract

To comply with a legal obligation

For our legitimate interests:

  • To select suitable employees, workers and contractors

*For special categories of information:

  • To exercise or perform employment law rights or obligations
Information about a disability, the effects of that disability, and special arrangements that may need to be made to the recruitment process as a result of that disability*
Establish whether you will be able to carry out a function that is intrinsic to the particular work

If you have accepted an offer of work from us that is subject to such a check: assess your fitness to work via a health questionnaire or medical report

To enter a contract

To comply with a legal obligation

For our legitimate interests:

  • To select suitable employees, workers and contractors

*For special categories of information:

  • To exercise or perform employment law rights or obligations
  • For the purposes of preventive or occupational medicine, or for the assessment of your working capacity
Health data and sickness records, including disability information*
  • Information about criminal convictions

To enable us to make recruitment decisions and assess suitability for particular work, we may process information about criminal convictions and offences (including alleged offences).  We will process this information for our legitimate interests in selecting suitable employees, workers and contractors, and to exercise or perform employment law rights or obligations.

  • Data necessary for the contract

The table at section 6 above identifies personal information that we may need to enter a contract with you.  If you don’t provide this data, we may not be able to proceed with the recruitment process or enter into the contract.

  • Statutory requirement to provide your personal information

In some circumstances, the provision of your personal information is a statutory requirement. This includes:

  • Documentation confirming your right to work in the relevant country – if you don’t provide this, we may not be able to enter into a contract with you.
  • The information regarding criminal convictions described at section 7 above, where we have stated in the job advertisement that this is a statutory requirement.
  • Sharing your personal information with third parties

We may share your personal information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

  • Other entities in the SYKES group of companies where the hiring manager is in another country, for system maintenance support and hosting of data;
  • Our service providers, including applicant tracking system providers, background check providers test providers and payroll providers;
  • With our clients for the purposes of validating our selection processes;
  • Health professionals and occupational health providers involved in your care, for the purposes of establishing whether you can undergo an assessment which forms part of the application process; considering reasonable adjustments to the recruitment process for disabled applicants; establishing whether you will be able to carry out a function that is intrinsic to the particular work;
  • Our professional advisors, including lawyers;
  • Other third parties as necessary to comply with the law.
  • Automated decision-making

We will not take any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you

  • Transferring your personal information outside the EU

We may transfer your personal information to Egypt, India, Philippines and United States of America in instances where the hiring manager is located there. To ensure that there are adequate safeguards for that transfer, we have in place a contract in a form approved by the European Commission.  You can access a copy of these by contacting our Data Protection Officer (see section 2 above). In addition, Sykes Enterprises, Incorporated in the United States of America are certified under EU-US Privacy Shield, a scheme approved by the European Commission as providing adequate safeguards for transfers of personal information to the USA.

  • Data retention

If you don’t start work with us following the recruitment process, we will retain your personal information for one year thereafter:

  • to allow us to establish, exercise or defend legal claims; and
  • for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for, or a similar role, becomes available again.

If you start work with us following the recruitment process, we will give you a copy of our Worker Privacy Notice, and will retain your personal information as detailed in the Worker Privacy Notice.

  • Your rights

You have the following rights:

  • Access: you can request a copy of your personal information that we hold, and check we are processing it lawfully.
  • Correction: you can ask us to correct your personal information if you don’t think it is accurate, complete or up-to-date.
  • Deletion: you can ask us to delete your personal information, if:
    • it is no longer necessary for the purposes for which we obtained it;
    • you withdraw your consent, and we have no other legal basis for the processing;
    • you validly object to the processing as described below;
    • we have unlawfully processed the data; or
    • we must delete the data to comply with a legal obligation.
  • Objection: if we process your personal information to perform tasks carried out in the public interest or on the basis of legitimate interests, you can object to this processing on the basis of your particular situation. We will only then continue the processing if we have overriding legitimate grounds for this, or the processing is to establish, exercise or defend legal claims. You may also object if we process your personal information for direct marketing purposes.
  • Restriction: you can ask us to restrict our processing of your personal information if:
    • you contest the accuracy of the data (for a period that enables us to check it);
    • our processing is unlawful, but you don’t want the data deleted;
    • we no longer need the data, but you require it to establish, exercise or defend legal claims; or
    • you have objected (as above) and are awaiting confirmation as to whether we have overriding legitimate grounds for processing.
  • Transfer: if our processing is based on your consent or necessary to carry out our contract with you, and is carried out by automated means, you can request a copy of the personal information you have provided to us and the transfer of this to someone else. Where technically feasible, you can ask us to transfer it directly.
  • Complain to the Supervisory Authority: we aim to resolve all complaints internally via our Data Protection Officer who can be contacted as described at section 2 above, but you do have the right to complain to the relevant Supervisory Authority at any time.

Please contact the Human Resources or Recruitment Department in the first instance if you require more information on these rights, or wish to exercise any of them.
LAST UPDATED – September 2018