Recruitment Privacy Notice
Effective as of August 17, 2022
P2H Inc. (“P2H”, “us,” or “we”) are committed to respecting your privacy and protecting your personal data. We define personal data broadly as information that directly identifies an individual or that makes an individual identifiable when combined with other information.
This Recruiting Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with P2H’s recruiting processes and programs. In case of a conflict between this Privacy Notice and applicable law, applicable law will govern.
This Privacy Notice only applies to the personal data of job applicants, potential candidates for cooperation or partnership, and those who participate in our recruiting programs and events. The personal data is submitted directly to P2H through the online application process, follow-up communications, and/or through alternative channels (e.g., via professional recruiting firms, recruitment websites etc.). While assessing your performance with the position specifications, P2H may also collect and process your personal data regarding cooperation with your current employer (e.g., if you are part of the senior leadership team of a target company). This Privacy Notice does not apply to the personal data of our employees, partners, clients, vendors or any other person from whom P2H collects personal data for other purposes.
By submitting your personal data to us, you acknowledge that:
- You have read and understood this Privacy Notice and agreed to the use of your personal data as set out herein.
- Your personal data may be transferred and processed worldwide, including in countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice.
- If you do not want us to process your Data, you are not required to provide any requested information. In such case we may not be able to review your application in full, since the lack of the information.
- All of your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Any inaccurate information can make you ineligible for cooperation.
- This Privacy Notice does not form part of any contract of employment, service provision agreement and other agreement of any kind, which is offered to candidates hired or engaged by P2H.
Personal data we collect
The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which the position you apply for is located, and not the country in which you reside. We usually collect personal data directly from you when you apply for a role with us, such as your name, address, contact information, photographs, work and educational history, achievements, identity documents, and test results. We also collect similar personal data about you from third parties, such as professional recruiting firms, your references, prior employers, P2H team members with whom you have interviewed or who recommended your candidacy, and, to the extent permitted by applicable law. We may also collect personal data about you online to the extent that you have chosen to make this information publicly available. For example, we may find your profile on professional social media websites (such as LinkedIn), and contact you about suitable positions.
Sensitive personal data is a subset of personal data that includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, and other categories as prescribed by law. We are not collect sensitive personal data about a candidate. We may also collect sensitive personal data to the extent that a candidate chooses, without being asked, to voluntarily disclose it during the recruiting process.
Use of your personal data
We collect and use your personal data for legitimate human resources and business management reasons, including:
- Identifying and evaluating candidates for potential cooperation, as well as for future roles that may become available;
- Maintaining records in relation to recruiting and hiring;
- Fostering our diversity and inclusion programs and practices;
- Conducting background checks, including;
- Protecting our legal rights to the extent authorized or permitted by law.
We may also use your personal data for P2H analytics purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and augment our ability to attract successful candidates.
Legal basis for processing your personal data
Our processing of your personal data for the purposes mentioned above is based:
- In part, on our legitimate business interests in evaluating your application to manage our relationship with you, to ensure that we recruit appropriate candidate, and to evaluate and maintain the efficacy of our recruiting process more generally;
- In part, on our performing contractual and precontractual measures relating to our potential cooperation relationship with you;
- In part, on our complying with applicable law with regard to personal data necessary to satisfy our legal and regulatory obligations;
- In part, on your consent, if we offer you the opportunity to participate in our optional recruiting programs.
Data recipients and international data transfers
Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying for is based. Individuals performing administrative functions and IT personnel (IT administrator, IT support etc.) within P2H may also have limited access to your personal data to the extent necessary to perform their jobs.
Except to the extent necessary to accomplish the P2H uses and purposes described in this Privacy Notice, we do not disclose your personal data to third parties. We do not otherwise share or sell your personal data to third parties.
In addition, we may disclose or transfer your personal data in the event of a reorganization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
Automated sorting of applications
We may use data analytics and algorithms to help us to review the large quantities of candidates and application data that we receive. These algorithms help us prioritize the application review process and sort candidates on the basis of professional characteristics that suggest strengths and capabilities necessary to perform the relevant role. The algorithms are designed to analyze the candidate’s application data and compare it to our historical data on previously successful and unsuccessful candidates.
The automated results are always considered in tandem with, and not in lieu of, human judgment. We evaluate each individual candidate on their own merits.
Certain roles may require specific prerequisites or skills (for example, fluency in a certain language, particular professional qualifications or certifications, or number of years in a similar role). Applications that do not meet those requirements will be automatically rejected.
If you accept an offer of cooperation with us, any relevant personal data collected during your pre-cooperation period will become part of your personall records and will be retained in accordance with specific country requirements and with the privacy notice applicable to P2H contractors and employees, which will be provided during the on-boarding process.
If we do not cooperate with you, we may nevertheless continue to retain and use your personal data for a period of time (which may vary depending on the country) for system administration purposes, to consider you for potential future positions, and to perform research. Thereafter, we retain a minimal amount of your personal data to record your recruiting activity with us.
We may want to remain in contact with you and consider you for future cooperation opportunities. In such an event, we will seek your consent to include you in one of our recruiting programs that provides you ways to further learn about and stay in touch with P2H, either prior to or after you formally apply for a job opportunity. Participation in these recruiting programs is entirely optional.
If you join a recruiting retention program, we retain your personal data for a period of time specific to that program, but if you wish to withdraw at any time, please contact us at email@example.com.
We use generally accepted standards of technical and operational security to secure your personal data. Only authorized personnel of P2H and of our third-party service providers are permitted to access personal data, and these employees and third-party service providers are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal data.
We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this Privacy Notice and applicable law.
In accordance with applicable law, you may have one or more of the following rights:
- A right to request information about the personal data we hold about you, including the details of how we use that information and who we share it with
- A right to request a copy of the personal data that we hold about you;
- A right to amend or rectify your personal data if any of the information held about you is incorrect or out of date;
- A right to portability of your personal data;
- A right to request erasure of your personal data;
- A right to demand that we cease the processing of your personal data or that we restrict the processing of your personal data;
- A right to withdraw your consent to the processing of your personal data, to the extent our processing relies on your consent as the lawful basis for processing. This right may not apply if there are other legal justifications to continue processing or we need to retain certain personal data where required or permitted under applicable law;
- In addition, and where granted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.
If you would like to make a request to access, review, correct, delete or port the personal data we have collected about you, to assert a right with regard to your personal data, or to discuss how we process your personal data, please contact either a member of the HR team member at firstname.lastname@example.org or Legal department at email@example.com.
To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Depending on the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in the P2H’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.
Social Media Tools
Our application process allows you to provide us with relevant personal data from information you have on third-party websites (such as LinkedIn, Google Drive, and Dropbox). If you choose to disclose your personal data from third-party websites, it will be used in accordance with this Privacy Notice.
If you have any questions about this Privacy Notice or if you would like to communicate with us, feel free to contact any of our HR team member at firstname.lastname@example.org or Legal department at email@example.com.