At Pro-India-Network (PIN) (“We”), we are committed to protecting and respecting your privacy.
As part of any recruitment process, we collect Personal Data which relates to you, the job applicant.
PIN are transparent about how Personal Data is processed and carries out this activity in accordance with applicable Data Protection Legislations and Regulations.
This Privacy Notice covers:
- Data which we collect from you directly during the recruitment process;
- Data which is provided to us by a third party (for example, a recruiter, former employer or referee); and
- Data we collect from you via your use of www.pindianet.com (the “website“).
For the purpose of this Privacy Notice and in line with applicable Data Protection legislation related to the jurisdiction in which you reside and, the jurisdiction in which the vacancy you have applied for is located, the Data Controller is:
Pro-India-Network, a company registered in Kolkata and, whose registered address is: First Floor, XI-11 &12 Block-EP, Sector-V, Salt Lake City, Kolkata, West Bengal, India.
By visiting our websites and applying for a job with us, you acknowledge the terms of this Privacy Notice and agree to our collection, use and disclosure of your Personal Data for the purposes stipulated herein in accordance with this Privacy Notice.
What Information Do We Collect About You?
We will process the following data about you during the recruitment process:
- Your name, date of birth, e-mail address, home address, phone numbers and passport or other identity documents you provide us with;
- Details of your qualifications, skills, experience and employment history (including any CV or Resume provided as part of your application), information about your current level of remuneration, including benefit entitlements and information gathered from interviews and assessments we invite you to participate in;
- Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
- Information about your entitlement to work in the jurisdiction where the job vacancy is advertised;
- Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief;
- Records of any correspondence we have with you. We may also monitor and record any communications we have with you, including phone conversations and emails to meet our regulatory and legal duties;
- Information that you provide by filling in application forms; and
- Details of your visits to our website recruitment page including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access;
- Where permitted by applicable law(s), we may collect information about you and update any existing information that we currently hold from other third-party sources, including publicly available data sources.
How Do We Collect Your Personal Data?
We collect your Personal Data in three main ways:
- Personal data that you give to us;
- Personal data that we receive from other sources; and
- Personal data that we collect automatically.
Personal data that you give to us
We mainly collect your Personal Data directly from you.
There are a number of ways in which you can share your Personal Data with us, including:
- When you make an application for a vacancy through our website recruitment page;
- Where you contact us proactively (for example, by phone, email or social media); or
- When you send us or submit your CV or Resume to us either by post or online.
In certain circumstances, we may process the Personal Data of third parties, such as an emergency contact or a referee. The Personal Data regarding third parties that you provide to us will be processed for the purposes of your application and to contact your next-of-kin in an emergency. Before you provide data relating to third parties to us, you should ensure you are permitted to do so and ensure that the third-party consents to our use, collection and disclosure of the third party’s personal data for the purposes stipulated herein in accordance with this Privacy Notice prior to making your application. You also confirm that you are authorised by the third party to provide such consent to us on the third party’s behalf.
Personal data we receive from other sources
We will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks.
From time to time as permitted by applicable law(s), we may collect information about you and update any existing information that we currently hold from other third-party sources, including publicly available data sources, and publicly available social networking sites such as LinkedIn and Facebook.
Personal data that we collect automatically
When you access the website recruitment page, we collect certain technical information about your device (as set out above). We use this data for statistical reporting about the website’s users browsing actions and patterns, and do not link it to any individuals.
Why Do We Collect and Process Your Information?
We process your personal data for the following reasons:
- To assess your application or to provide you with information about potential vacancies;
- To assess your qualifications for a particular vacancy;
- To verify information, we have received from third parties (for example, recruiters), or through information requests (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with applicable laws);
- To promote diversity and prevent discrimination;
- To ensure the quality and effective operation of the website;
- To provide you with information that you request from us;
- As part of the research that we conduct about our website for statistical purposes;
- For internal purposes, such as internal reviews, website and system administration, internal audits; and
- To comply with our legal and regulatory obligations.
Legal Bases for Processing Your Personal Data
There are a number of legal bases which allow us to lawfully process your Personal Data, and which may apply depending on the laws of the relevant jurisdiction:
- Where using your personal data is necessary for us to carry out our obligations under our contract with you;
In most cases, we process your data in order to enter into contracts with you relating to your employment or engagement with us.
- Where the processing is necessary for us to carry out our legal obligations;
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the INDIA before employment starts.
- Where using your data is in our legitimate interests;
We have a legitimate interest in processing personal data during the recruitment process and in keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims. Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of employees or workers and have concluded that they are not.
- Processing your special category personal data and/or criminal records data;
We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.
Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our legal obligations and exercise specific rights in relation to employment.
How Long We Will Keep Your Data For?
We process and store your personal data to the extent necessary for the duration of the application process. If your application for employment is successful, your personal data will be transferred to your personnel file. The periods for which your data will be held will be as detailed in the standards on the handling of staff data policy. However, if your application for employment is unsuccessful, your personal data and/or application documents will be erased 12 months after the application process is completed.
This does not apply if your data is processed and stored in order to assert or exercise legal claims, or to defend against legal claims (duration of litigation) or we obtain separate consent from you to keep your application documents longer.
How Do We Keep Your Personal Data Secure?
- Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email);
- We use a variety of technical and organisational methods to secure your Personal Data in accordance with applicable laws;
- We are committed to protecting the security of the Personal Data you share with us. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk;
- We require our vendors and suppliers to keep the Personal Data that we provide to them securely, both in transit and once received by them. This includes the use of encryption methods, where appropriate.
Who Do We Disclose Your Information To?
- Sharing your data within our organisation;
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
We may also share your Personal Data with other members of our corporate group, depending on the role you have applied for.
- Sharing your data with our service providers;
We disclose information to service providers who provide services on our behalf. Your data will only be used by our third-party providers to provide the requested services to us and each service provider is subject to a set of terms consistent with this Privacy Notice. We use the following types of third-party providers to provide us with services:
- Providers of website management and hosting services;
- Providers of email communication tools and webinar platforms;
- Providers of professional services, such as accountants and legal advisors, where necessary; and
- Third-party auditors, where necessary to meet our legal and regulatory obligations;
Sharing your data with potential purchasers of PIN or its assets.
In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
- Sharing your data where we have a legal or regulatory obligation to do so;
If we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or to protect our rights, property, or safety, or the rights, property or safety of our customers, or others.
We will not otherwise share your data with third parties unless your application for employment is successful and we make you an offer of employment. We will then share your data with your former employers to obtain references for you, employment background checks providers to obtain necessary background checks and the relevant agency to obtain necessary criminal records checks.
Sharing Personal Data overseas
Some of our service providers and group companies are located outside of the ASIA, or Singapore (as the case may be).
If we share your Personal Data with those organisations, we will ensure that appropriate safeguards are in place to protect your Personal Data and that transfer of your Personal Data is in compliance with applicable data protection laws.
Where necessary, we have ensured that service providers (including other PIN Group affiliates) sign standard contractual clauses as approved by the Asian Commission or other Supervisory Authority with jurisdiction over the relevant data exporter.
You have various rights in relation to the data which we hold about you, as described below. To get in touch with us about any of these rights, please use the contact details set out below. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable Data Protection law (subject to any extensions to which we are lawfully entitled).
Please note that we may keep a record of your communications to help us resolve any issues which you raise.
- Right to object;
This right enables you to object to us processing your Personal Data, if such right is provided under the data protection laws of the applicable jurisdiction.
- Right to withdraw consent;
Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.
- Right of access;
You may ask us for: (a) a copy of the information we hold about you; and (b) information about the ways in which such personal data has been or may have been used or disclosed by us within a year from the date of the request, at any time. If we provide you with access to the information we hold about you, we will do so within a reasonable time and not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.
- Right to erasure;
You may have the right to request that we “erase” your Personal Data in certain circumstances, under the applicable data protection laws of the applicable jurisdiction. Normally, this right exists where:
- The data is no longer necessary;
- You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;
- The data has been processed unlawfully;
- It is necessary for the data to be erased in order for us to comply with our obligations under law; or
- You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
- Right to restrict processing;
You may have the right to request that we restrict our processing of your Personal Data in certain circumstances, under the applicable data protection laws of the applicable jurisdiction. For example, if you dispute the accuracy of the Personal Data that we hold about you or you object to our processing of your Personal Data for our legitimate interests. If we have shared your Personal Data with third parties, we will notify them about the restricted processing.
- Right to rectification;
You have the right to request that we rectify any inaccurate or incomplete Personal Data that we hold about you. If we have shared this Personal Data with third parties, we will notify them about the rectification. You may also request details of the third parties that we have disclosed the inaccurate or incomplete Personal Data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
- Right of data portability;
If you wish, you may have the right to transfer your Personal Data between service providers. In effect, this means that you are able to transfer the details we hold about you to another third party, under the applicable data protection laws of the applicable jurisdiction. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.
You may seek to exercise any of these rights by updating your information online (where possible) or by sending a written request to firstname.lastname@example.org.
Right to complain
You also have the right to complain to your applicable Data Protection Authority.
If You Do Not Provide Us with Your Personal Data:
- You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.