ChangeGroup Sweden AB
EU Privacy Information Notice for Job applicants
What is the purpose of this document?
This Privacy Information Notice (“Privacy Notice”) applies to ChangeGroup Sweden AB, org. no. 556835-1646 (“ChangeGroup”). We are, being a data controller, responsible for deciding how we hold and use personal information about you. You are being given a copy of this privacy notice because you are applying for work with us (whether as an employee, worker, or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of recruitment, and how long it will be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU 2016/679) (GDPR).
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
The kind of information we hold about you
In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- Your name, address, date of birth, employment history, information of your qualifications and education, and other job-related information (including contact information and eligibility to work).
- Any information you provide to us during an interview.
- Any information that you provide to us as part of the application process including any test results.
We may also collect, store and use the following "special categories" of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
For specific information on how and why your information is processed see tables below.
How is your personal information collected?
We may collect personal information about job applicants from the following sources:
- You, the job applicant, either directly or via our online recruitment system Team Tailor.
- a recruitment agency, from which we may collect the following categories of data: name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications.
- a background check provider.
How we will use information about you
We will use the personal information we collect about you for the following purposes:
- Assess your skills, qualifications, and suitability for the role applied for.
- Carry out background and reference checks, where applicable and only in accordance with local law.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
- Save your job application or personal data you have provided us on a speculative basis in order to be able to contact you if a relevant position is available in the future.
Further information on usage of your personal information
We will use the categories of information set out in the list above under the heading ‘The kind of information we hold about you’ in certain circumstances. The purposes and additional information pertaining to usage of your personal information are listed below.
Recruitment
What we do:
Categories of personal data:
Legal basis:
Retention period
- Assess your skills, qualifications, and suitability for the role applied for.
- Carry out background and reference checks, where applicable and only in accordance with local law.
- Communicate with you about the recruitment process.
- Keep records related to our hiring process.
- Save your job application or personal data you have provided us on a speculative basis in order to be able to contact you if a relevant position is available in the future.
CVs, name, address, date of birth, employment history, qualifications, education, other job-related information such as contact information and eligibility to work.
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
For special categories of data, the legal basis for processing is that this is necessary within the field of employment (article 9.2 (b))
Stored in accordance with local law requirements (2 years).
Your rights: You have the right to request access to your personal data, rectification, erasure, restriction of processing of your personal data and data portability. For more information on the rights and on how to exercise them please view information below in this notice.
Where you have provided us with your personal data on a speculative basis, rather than in order to apply for a specific role, we may also store your personal data in accordance with our retention policy (see below) in order to contact you about future roles that may be of interest to you.
We may also use your personal data where you have been unsuccessful in your application for a specific role and we may want to use your personal data in accordance with our retention policy (see below) in order to contact you about future roles that may be of interest to you.
It is in our legitimate interests to use your personal data in the ways listed above in order to decide whether to appoint you to the role or notify you of any relevant vacancies since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract with you.
Having received your CV and covering letter and/or your application form and the results from any tests, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we may then take up references and/or carry out a criminal record and/or carry out any other checks before confirming your appointment. This will only occur where we are legally required to do so and will only be carried out in accordance with local law.
If you fail to provide personal information
It is necessary bur not legally mandatory that you provide certain personal data to us. If you, when requested, fail to provide information which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). The law may require us to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
- Where we are legally required to carry out criminal record checks for those carrying out the role.
- Where, due to the nature of the work that we do, the Foreign Exchange industry (and certain customers in particular) requires a high degree of trust and integrity since it involves dealing with high volumes of money and so we would like to ask you to seek a basic disclosure of your criminal records history.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. Criminal conviction checks will only be carried out in accordance with local law.
Automated decision-making, including profiling
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in certain circumstances. However, you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Data sharing
Why might you share my personal information with third parties?
We will only share your personal information with third parties (which includes Team Tailor and other companies within our group of companies) for the purposes of processing your application. In the table below, you will find information about which third parties we may disclose personal data to and which categories of personal data that will be disclosed in such a case.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share your data with:
Categories of personal data that are shared:
Team Tailor
Information relating to your application to work for us.
We only process your personal data in the EU/EEA.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
How long will you use my information for?
We will only retain your personal data for as long as it is needed for the purposes for which we collected the personal data and as described in this privacy notice. More specific retention periods are provided in the tables above under the heading “Retention period”.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no compelling reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party (data portability).
If you want to review, verify, correct, restrict or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.
Right to withdraw consent
Where you have provided consent to us processing your personal information for the purposes of the recruitment exercise, you have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
Compliance Contact
We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer by emailing: changegroupdpo@prettys.co.uk.
Right to lodge a complaint with a supervisory authority
You have the right to make a complaint at any time to the Swedish Authority for Privacy Protection, the Swedish supervisory authority for data protection issues.
Their contact details are:
Telephone number: 08-657 61 00
E-mail-address: imy@imy.se
Postal address: Integritetsskyddsmyndigheten, Box 8114, 104 20 Stockholm
