This Privacy Notice explains how we collect and process personal data relating to job applicants.
1. Introduction
CompatibL Technologies LLC, with its registered office at 100 Overlook Center, Princeton, NJ, USA, acting for itself and on behalf of its affiliated group entities (hereafter, the “Company”, “CompatibL”, “we”), is the controller of the personal data described in this Candidate Privacy Notice. Where you apply for a position with a CompatibL group entity outside the United States, that entity is the controller for your application, and its details are provided in the job advertisement or on request. As part of our recruitment process, the Company collects and processes personal data relating to job applicants. This Candidate Privacy Notice explains our data processing operations and the rights you are granted under applicable data protection laws, including the EU and UK General Data Protection Regulations (GDPR) and the UK Data Protection Act 2018.
2. What Type of Information Do We Collect?
We collect and process your personal data when you apply for a vacancy. The personal data we may collect in relation to your application includes:
- Your name
- Phone number (or other contact details)
- Email address
- Home address
- Details of your qualifications, skills, experience and employment history, including other personal data which is included in your resume
- Information about your right to work in applicable countries
- Information generated during the recruitment process, such as interview notes, assessment or test results, and our correspondence with you
We do not ask you to provide special categories of personal data (such as data revealing your health, racial or ethnic origin, religious beliefs, or trade union membership). If you volunteer such data, e.g., in your resume, or if it becomes relevant, for example, where health information is needed to arrange reasonable adjustments for an interview, we process it only where a condition under Article 9 of the GDPR applies, such as your explicit consent or the performance of obligations under employment law. Information about your right to work may reveal your nationality or immigration status and is processed to comply with our legal obligations.
3. How Do We Collect Information About You?
In most cases, we receive your personal data directly from you, when you apply for our advertised jobs or through interviews and job assessments. We may also receive your personal data from third parties, such as recruitment agencies, job boards or professional networking sites (for example, on LinkedIn, where you have made your profile available to potential employers), individuals who refer you to us, and, with your prior consent, your former employers and background check providers. Where we obtain your personal data from a source other than you, we will inform you of that source when we first contact you or upon your request.
4. How Is Your Information Used?
We process the personal data listed in Section 2 for the purpose of managing your application to our vacancies. Our lawful bases for this processing are: (a) taking steps at your request prior to entering into an employment contract (Article 6(1)(b) GDPR); (b) compliance with our legal obligations, such as verifying your right to work (Article 6(1)(c) GDPR); (c) our legitimate interests in attracting, evaluating, and selecting candidates for our vacancies (Article 6(1)(f) GDPR), which we have assessed against your interests, rights and freedoms; and (d) your consent, where we rely on it for specific activities such as retaining your data for future opportunities or contacting your references.
Providing the personal data described in Section 2 is necessary for us to consider your application; if you do not provide it, we may be unable to progress your application. In some cases, we are also legally required to verify your right to work. Where this applies, providing that information is a statutory obligation under local law. We do not make recruitment decisions based solely on automated processing, including profiling.
4. How Is Your Information Used?
Generally, we will collect or process the personal information to:
- Assess your candidacy for the applied role
- Verify background checks and employment records
- Comply with federal laws, state laws and all applicable regulations
- Communicate with you regarding your suitability for the role.
CompatibL may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. CompatibL may also process your information to carry out its obligations and exercise specific rights in relation to employment, or where there is a need for us to investigate, prevent, or take action if we believe someone may be using information for illegal activities or in a way that is contrary to our policies.
5. Who Has Access to Your Data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, interviewers involved in the recruitment process, managers in the business area with a vacancy.
With your prior informed consent, CompatibL may share your data with former employers to obtain references for you and with employment background check providers to obtain necessary background checks. We may also disclose personal data where required by law, regulation or court order, or to establish, exercise or defend legal claims.
6. International Data Transfers
CompatibL operates through group entities and offices in the United States, the United Kingdom, the European Union, and Singapore, and your personal data may be accessed from, or transferred between, these locations for the purposes described in this Notice. Where personal data protected by the EU or UK GDPR is transferred to a country that is not recognized as providing an adequate level of data protection, we implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, supported by additional technical and organizational measures where necessary. You may request further information about these safeguards, or a copy of the relevant clauses, by contacting policy@compatibl.com
7. For How Long Does CompatibL Keep Your Data?
If your application for employment is unsuccessful, CompatibL will hold your data on file for 12 months after the end of the relevant recruitment process. If you agree to allow CompatibL to keep your personal data on file, CompatibL will hold your data on file for a further 12 months for consideration for future employment opportunities.
At the end of that period, or once you withdraw your consent, your data is securely deleted or destroyed, unless we are required or permitted to retain it for longer in order to comply with a legal obligation or to establish, exercise, or defend legal claims. If your application for employment is successful, personal data 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 a new employee privacy notice.
You can request deletion of personal data at any time by contacting policy@compatibl.com. We will comply with your request unless we have a legal obligation or another lawful ground to retain the data.
8. What Are Your Rights Around Your Personal Information?
The GDPR grants you the following rights, which you can exercise by contacting policy@compatibl.com
- Right of access
- Right of rectification
- Right to erasure (“right to be forgotten”)
- Right to restriction of processing
- Right to object
- Right not to be subject to a decision based solely on automated processing, including profiling
- Right to data portability
- Right to withdraw consent at any time, where processing is based on your consent, without affecting the lawfulness of processing carried out before withdrawal
- Right to lodge a complaint with a supervisory authority, such as the data protection authority in the country where you live or work (in the UK, the Information Commissioner’s Office)
Some of these rights apply only in certain circumstances. Exercising your rights is free of charge, and we will respond to your request within one month of receipt.
9. How Can You Contact Us?
If you have any questions, requests or concerns related to our processing activities or would like to exercise any of the rights described herein, you should contact: policy@compatibl.com. For more information on our data processing activities, please refer to our Group Privacy Policy.