Recruitment Policy

Introduction

At Banyan Solutions Ltd. (trading as TBSCG) we are committed to respecting your privacy and ensuring compliance with applicable data protection and privacy laws and regulations.

This recruitment Privacy Policy (“Policy”) informs you about how TBSCG processes information it collects about you during recruitment activities. The policy sets up what kind of Personal Data TBSCG may collect about you and from other sources, how TBSCG processes your Personal Data during its recruitment activities, and what rights you have in relation to such data.

Additional privacy information may be provided to you via supplements and other notices. If there is a difference between such supplements and this Policy, the notices should be considered first.

Definitions

Personal Data - is any information relating to you or another identifiable individual.

Sensitive Personal Data – specific categories of Personal Data as defined under applicable laws that may be processed only when there is a lawful basis to do so or with the individual’s consent. These categories include but are not limited to Personal Data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union memberships, processing of genetic data, biometric data or data which concerns their health, sex life or sexual orientation.

Your Rights

With respect to the processing of your Personal Data, you will always have the rights as provided by applicable local laws, such as:

  • Right to access;
  • Right to be informed;
  • Right to rectification;
  • Right to erasure;
  • Right to restrict processing;
  • Right to data portability;
  • Right to object.

There will be no adverse consequences in you exercising your rights as mentioned above.

In case you revoke your consent or object to certain processing activities, TBSCG may be unable to continue the recruitment process with you.

If you wish to exercise any of your rights, please see Section 11 for more details on whom to contact.

What Personal Data does TBSCG collect?

TBSCG collects Personal Data directly from you as well as from other available sources to the extent relevant and permitted by applicable local law. TBSCG endeavours only to collect Personal Data that is necessary for the purpose(s). Subject to applicable local law and practice, the categories of Personal Data that are typically collected and processed in the context of recruitment are as follows:

  1. Information You Provide:

When you apply for a position or otherwise interact with TBSCG (either directly, through an agency or third party), you may be asked to provide TBSCG with information such as:

  • Your name;
  • Address;
  • Telephone number;
  • Email address;
  • Your competences and/or skills,
  • Experience and education;
  • Employment history;
  • Third party references;

Depending on the geographical location of the position you are applying for, you may be offered the opportunity to provide diversity data such as race, gender and veteran status. Provision of this diversity data is optional, and no employment decision will be made on the basis of this data.

  1. Technical Information:

When you access our services online, our web servers automatically create records of your visits. These records can include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information. When you use our services or otherwise interact with the company over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to TBSCG by the telecommunications operator as a standard part of that communication. See also our Cookie Policy.

We may also collect other information, such as information found from public sources as well as information related to credit or background checks, depending on the position you are applying for, and where necessary for the recruitment activities.

What will TBSCG do with your Personal Data?

TBSCG will collect, use, store and otherwise process your Personal Data for the purposes of TBSCG’s recruitment or resourcing activities. Additionally, your Personal Data may be processed for other purposes you have given us consent to do so, or in cases where another legal basis applies or where legally allowed to do so. Whenever necessary, and subject to statutory record-keeping requirements, TBSCG will delete and/or anonymise Personal Data that is no longer needed. If there has not been any recent activity on your profile, we may delete your profile after a reasonable time in compliance with applicable laws. Otherwise we will maintain your profile for as long as you remain active in our system for you to be able to apply for available positions which may become available to you from time-to-time.

TBSCG will process your Personal Data for the following purposes:

  • Communicating with you, regarding recruitment activities, such as:
    • To obtain additional information, if necessary;
    • To inform you of current available vacancies;
    • To provide you with information relating to your application and to fulfil your requests.
  • Managing recruitment and resourcing activities, including activities related to organisational planning. In the interest of recruitment activities, we may use your information:
    • To arrange and conduct interviews and assessments;
    • To evaluate, select and hire applicants;
    • To conduct background and credit checks and assessments, as required and/or permitted by applicable local law;
    • To contact third party references provided by you to evaluate your previous performances;
    • Or as otherwise necessary in the context of recruitment activities.
  • If you are hired by TBSCG, for populating your employee file and various systems and tools used in connection with employment. Upon hire, your Personal Data will be subject to the TBSCG Privacy Notice in lieu of this Policy.
  • Legal and regulatory compliance, including obtaining and releasing personal data as required by law, judicial organisations or practice in order to comply with legal obligations imposed on us.  

TBSCG processes your personal data in accordance with several legal bases, depending on the type of data and purpose of the processing. Under most circumstances, TBSCG’s processing of your Personal Data in the recruitment context is based on your request in the anticipation of entering into an employment agreement with TBSCG. TBSCG will also process this information, where required, to comply with legal obligations to which it is subject, such as governmental reporting obligations. In some circumstances, TBSCG will process your Personal Data in accordance with its own legitimate interest in operating its business, including conducting the above described activities for internal administrative purposes and ensuring network and information security. A different legal basis may be provided at the point where Personal Data is collected.

How is Sensitive Personal Data treated?

TBSCG aims to limit the collection of Sensitive Personal Data and shall only collect Sensitive Person Data if there is a legal justification for processing it, or if it is collected and processed with your expressed consent.

TBSCG recognises the additional need to protect Sensitive Personal Data. All Sensitive Personal Data is processed in strict compliance with applicable local law and only by a restricted number of individuals, who have a clear and justified need to know such information.

Sensitive Personal Data may be processed where necessary to enable TBSCG to exercise its legal rights or to perform its legal obligations in the field of employment law or related fields of law.

Who has access to your data?

At TBSCG, we have a responsibility to implement appropriate access control measures to ensure that your Personal Data is only accessed by persons having a clear need to know such information.

The extent to which your Personal Data are made accessible will depend upon the nature of the data concerned. Prior to hire, your Personal Data is not made widely available. Some Personal Data, such as your resume, job history, and other information relevant to assessing your ability for the position to which you have applied, are made available as needed to the TBSCG team you are seeking to join, others within TBSCG with a stake in the applied for role and appropriate members of the TBSCG Human Resources Department. Except as needed to assess your qualifications for the role, access to most of your Personal Data is restricted to certain experts (e.g. Human Resources, IT or Legal) to the extent necessary to perform their work tasks.

Transfer of Personal Data  

TBSCG will not sell, lease, rent or otherwise disclose your Personal Data except where the following may apply:

  • Consent – TBSCG may share your Personal Data if you have given consent for the company to do so.
  • TBSCG and authorised third parties – TBSCG may share your Personal Data with authorised third parties who process Personal Data for TBSCG for the purposes described in this Policy or otherwise provide recruitment related services to TBSCG. In such cases, TBSCG will ensure there is a genuine need to transfer your Personal Data and that suitable measures are in place to safeguard the processing of your Personal Data by authorised third parties.

Authorised third parties include, for example, recruitment agencies, professional advisors, external legal counsel, recruiting systems providers, providers of assessments and other third party suppliers.

Authorised third parties may have technical access to your Personal Data in the course of providing their services but will be contractually restricted (or subject to a professional or statutory duty of confidentiality) from processing you Personal Data for other purposes. TBSCG also requires these third parties to act consistently with this Policy, using appropriate security measures to protect your Personal Data.

  • International transfers of Personal Data – TBSCG is a global company that has affiliates, business processes and technical systems that cross borders. This means that your Personal Data may be transferred across international borders to countries other than the one you are applying to as an applicant. These other countries may not have equivalent laws providing specific protection or rights in relation to Personal Data, or they may have different rules on privacy and data protection. TBSCG takes steps to ensure there is an adequate legal basis for international transfers of Personal Data and that suitable protection for your Personal Data is provided by applicable law. Examples of such steps include use of appropriate technical and organisational security measures to protect your Personal Data. You may contact the TBSCG GDPR Team at gdpr@tbscg.com to obtain additional information about the safeguards taken by TBSCG in relation to these transfers.
  • Mandatory disclosures – At times, TBSCG may be required by or under mandatory law to disclose your Personal Data to certain authorities or other third parties – for example, to government agencies responsible for the employment activities, statistical information or to the police or other law enforcement agencies, for example in context of conducting a criminal investigation.
  • Mergers and acquisitions – Where TBSCG takes steps to sell, buy, merge or otherwise reorganise its business in certain countries, the company may be required to disclose Personal Data to prospective or actual purchasers and their advisers. In such circumstances, TBSCG will take all reasonable steps to ensure that appropriate measures to protect Personal Data are taken by such prospective or actual purchasers and their advisers.
  • Other – TBSCG may disclose your Personal Data if it is necessary to protect your vital interests. TBSCG may also disclose and otherwise process your Personal Data in accordance with applicable law to defend TBSCG’s legitimate interests, for example, in legal proceedings.  

What steps are taken to safeguard your Personal Data?

TBSCG takes steps to enforce our internal policies and guidelines throughout the company across an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. These steps enable and promote online security, physical security and consideration of data loss and/or risks presented by the processing and the nature of the data being protected. In addition, we limit our access to our data bases containing Personal Data to authorised persons having a justified need to access such information.

Data Quality

TBSCG aims to keep the Personal Data we process accurate and to delete incorrect or unnecessary Personal Data. Where applicable, TBSCG encourages you to contact the GDPR Team (gdpr@tbscg.com) to keep any Personal Data the company may hold of you up to date. Where permitted or required by applicable local law or subject to your consent, we may use public sources in order to verify that Personal Data we process is correct.

Whom to contact?

TBSCG is the controller of your Personal Data. If you have any queries about your Personal Data, you should contact the relevant recruiting personnel through provided contacts.

If you want to exercise your rights as described in previous sections of this Policy, you may make a request in writing through provided contacts.

TBSCG may need to identify you and to ask for additional information to be able to fulfil your request. TBSCG will fulfil your request within the timeframes required by applicable local law or, in the absence of such timeframes, within a reasonable time.

TBSCG has a dedicated team to deal with any queries regarding Personal Data and Privacy. They can be contacted in writing at the following address:

GDPR Team

Banyan Solutions Ltd.

Market House

29 High Street

Uxbridge

UB8 1JN

OR by email at: gdpr@tbscg.com

Changes to this Policy

TBSCG may change this policy or change, modify or withdraw access to this site at any time with or without notice. However, if this policy is changed in a material, adverse way, TBSCG will post a notice advising of such changes at the beginning of this Policy. We recommend you revisit this policy from time to time to learn of any such changes to this policy.