KARGO
EU CANDIDATES’ PRIVACY POLICY
April 2023
_____________________________________
1. Background to
this Candidate Privacy Promise
This Candidate
Privacy Promise applies to all recruitment candidates in the
course of application for employment in any of our EU offices, with
regards to personal data related to their application and potential employment
for the Company as referred to below.
Processing
of personal data is necessary for the reasons set out in
this Privacy Policy. If you wish to object to processing of
personal data relating to you, or require us to delete it, this could lead to
us being unable to comply with the application process or other legal obligations.
The Company
processes personal data in regard to processing your application for recruitment, and does so in accordance with all applicable
laws including the EU General Data Protection Regulation (GDPR) and applicable
national laws, as further described in this Privacy Policy. It applies to
personal data that the Company needs to run our business and manage our
relationship with you, at all stages during the recruitment process. We process
personal information for a range of purposes relating to general recruitment
activities as well as the recruitment process and this may include your
application, assessment, pre-employment screening, and your worker permissions.
If you become
an employee, then we will inform you of other data processing necessary in
connection with your employment.
If you want
to learn more about the way the Company processes personal data in connection
with its digital data business, or if you want to exercise your rights or
manage your choices, please the KARGO’s Privacy Policy: https://www.kargo.com/privacy.
2. Data
Controller and DPO Details
The entity that decides on the
purposes for which and ways in which personal data relating to you is processed
is:
·
KARGO Ireland Limited if
you apply to work in our Irish offices situated at Waterford Institute of
Technology West Campus, 2nd floor, Carriganore,
Waterford, Ireland
For any personal data-related
issues you can contact:
(a)
The data privacy team at privacy@kargo.com
(b)
Or the Data Protection Officer at dpo@kargo.com
at:
Kargo Global LLC, 826 Broadway, 4th Floor, New York, NY 10003
3. What types of
personal data does the Company process?
This Privacy Policy
covers the Company’s processing of “personal data”, which is defined as
follows:
‘Personal
data’ - means any information relating to you (or any other identified or
identifiable person), which may include name, address, telephone numbers,
education, experience and qualifications, household, tax and social security
information, and details of or any change in your personal circumstances which
affects, or may affect, your tax status or right to work in the role for which
you are applying.
'Special
categories of personal data' - means personal data revealing
racial or ethnic origin, political opinions, religious or philosophical
beliefs, or trade union membership, and the processing of genetic data, biometric
data for the purpose of uniquely identifying a natural person, data concerning
health or data concerning a natural person’s sex life or sexual orientation.
This data
will only be processed for certain narrowly defined purposes.
The personal
data the Company may hold includes:
a)
Your CV, application letter, tests, or application forms
b)
References
c)
Records relating to your employment history, such as
training, appraisals, other performance measures and, where appropriate,
disciplinary and grievance records;
d)
Correspondence, such as offer letters;
e)
Data regarding past, desired and possible compensation:
basic salary, benefits, bonuses, etc.;
f)
Contact and emergency contact details;
g)
Personal data needed for any equal opportunities
monitoring policies;
h)
Criminal convictions data: the Company does not currently
process such data and would do so only where this is expressly permitted or
required by the law and in accordance with all applicable restrictions
i)
CCTV Images and video footage of what takes place at our
office locations (e.g. when you attend an interview), at all times of day, in
real time.
We operate CCTV cameras within the following EU offices ( ). Footage is
recorded for the following purposes: health and safety, prevention of crime and
theft of property and is usually held for a maximum of days from the time of
recording.
At
our discretion, we may disclose CCTV footage and/or personal data in response
to valid requests from the police and other statutory law enforcement agencies
or if otherwise required by law.
j)
Nationality / visa / right to work permit information; (e.g. passport, driving licence, National Insurance numbers);
k)
Special categories of personal data:
Health: We may keep
(when necessary) personal data relating to your health or medical conditions.
This personal data will be used in order to comply with our health and safety
and occupational health obligations – to consider how your health affects your
ability to do your job and whether any adjustments to your tasks or the
workplace might be needed. For other special categories such as personal
sensitive data revealing your racial or ethnic origin, political opinions,
religious and philosophical beliefs, trade union membership, biometric data or
sexual orientation, we will always obtain your explicit consent before
processing.
Also, in the cases of compliance
with laws, carrying out obligations related to employment rights, protection of
health or safety, we would then also process your personal data.
4. Why does the
Company need to collect and process this personal data?
The Company
keeps and processes personal data relating to you in order to:
·
manage and process your
application and for general recruitment purposes, on the basis that it is in
the legitimate interests of the Company to do so;
·
comply with applicable laws
or regulations;
·
in the case of special
categories of information (as per the details in section 3) where we have
obtained your explicit consent or where permitted by
applicable laws.
5. Do we
transfer your personal data?
We may
transfer personal data about you to other Company offices for purposes
connected with your recruitment application or the management of the Company’s
business. At the date of this Privacy Promise, the Company has offices and
staff in: New York, Waterford….
We may use
third party data processors to manage personal data in connection with our
recruitment processes, who may be located within the EU, the EEA or Switzerland
or elsewhere. We only transfer data within the EU, EEA or to third party
countries based on appropriate transfer mechanisms when needed such as the
EU-US Privacy shield or EU model clauses.
6. Data retention
For job
applicants and candidates: not more than 180 days after the role has been
filled (unless you ask or authorise us to keep it for
longer)
7. Your rights
You have a number of rights with regard to your personal data, i.e.:
·
The right to be informed
·
The right of
access
·
The right of rectification
·
The right to
erasure
·
The right to
restrict processing
·
The right to data
portability
·
The right to
object
·
The right not to
be subject to automated decision-making
We are not always required to
ask for your consent for the processing of personal data (for example, in case
of a legitimate interest). However, where we do rely on any consent that you
have given, then you are always allowed to withdraw your consent at any time
(though the processing that took place before withdrawal will still be legal).
In certain circumstances it may not be possible for these rights to be
exercised in full or at all as they are closely related to your application or
applicable employment laws. We will explain any actions we have taken or not taken in relation to any request you make.
If you believe that your
rights have not been respected at any time then you also have a right to
complain to the Supervisory Authority in your country (in Ireland, the Data
Protection Commission, “DPC”; in the UK, the Information Commissioner’s Office,
“ICO”; in France, the Commission nationale de l'informatique et des libertés, “CNIL”;
in Spain, the Agencia Española de Protección
de Datos, “AEPD”…).