Prosegur Foreign Exchange
EU Privacy Information Notice for Candidates/ Applicants
What is the purpose of this document?
This Privacy Information Notice applies to Prosegur Foreign Exchange ("we" or "us"). This means that we are 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 the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU 2016/679) (GDPR). We are the "data controller" for the processing of personal data obtained during the recruitment process. The contact details and how to contact the Data Protection Officer are detailed below in this document.
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.
- Kept securely.
Purposes, processing activities and legal basis
In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:
- Review of application and CV, and preparation of employment contract
When we receive your application, we will read it and select the persons who we will call for an interview. The selection is based on your qualifications in relation to the specific position(s). You will be called for the interview by email or telephone.
As part of the recruitment process, we will receive and process the personal data that you have included in your application, CV and any other material which you may have forwarded along with your application and information you provide during the potential interview.
We may also ask you to send us additional information. The information obtained in this connection will include information about your previous employments, including information relating to work assignments, skills and performance, eligibility to work in Denmark, and information about your personal appearance and interpersonal skills. We will also obtain other information about you if we consider such information to be necessary for the assessment of your application.
The legal basis for our processing is article 6(1)(f) of the GDPR as we pursue our legitimate interest in reviewing your application and CV, and article 6(1)(b) of the General Data Protection Regulation when preparing the employment contract.
During the recruitment process relating to some positions, we may use a personality test and/or a competency test. The legal basis for our processing is article e 6(1)(f) of the GDPR as we pursue our legitimate interests in conducting such tests.
If we decide to offer you the role, we may then take up references. If we wish to obtain information about you from your current or former employer using your references, we will first ask for your consent. The legal basis for our processing your references is article 6(1)(a) of the GDPR. You always have the opportunity to withdraw your consent.
We process special categories of personal data.
In case of any criminal convictions, we will process such information if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We require criminal records to be checked for the following reasons:
- 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.
The legal basis for our processing your personal data related to criminal convictions is section 8(3) of the Danish Data Protection Act. You always have the opportunity to withdraw your consent.
Speculative applications:
Where you have provided us with your personal data on a speculative basis, rather than 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.
The legal basis for our processing your personal data related to speculative applications is article 6(1)(f) of the of the GDPR, as it is our legitimate interest in assessing those applications.
Upon your consent, 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.
How is your personal information collected?
We may collect personal information about candidates from the following sources:
- You, the candidate, either directly or via our online recruitment system Team Tailor.
- Upon your consent, we will process personal information with regard to references and criminal convictions.
- As part of our recruitment process, we will conduct a credit check as the position which is applied for is considered a particularly trusted position. The legal basis for our processing is article 6(1)(f) of the GDPR as we pursue our legitimate interests conducting a credit check where applicants are considered for a particularly trusted position.
If you fail to provide personal information
If you fail to provide information when requested, 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.
Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. 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 the group of companies) for the purposes of processing your application. 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.
Transfer of personal data to third countries
In connection with our recruitment process we transfer your personal data personal to the group companies located in third countries. The third countries include e.g. United Kingdom.
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?
In case you have been informed of a rejection to your application, we will retain your personal information for a period of 6 months after we have communicated to you our decision. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely delete your personal information in accordance with our data retention policy.
If you have applied on a speculative basis, rather than for a specific role, or if you have been unsuccessful in your application for a specific role, then we will store the personal information that you have provided for the period you have consented to. We do this in order to be able to consider whether a future vacancy may be appropriate for you and to contact you to inform you of this. After this period we will securely delete your data.
Where you have consented for us to keep your personal data in order to potentially be considered for any future vacancies, we will keep your personal data for period to which you have consented to.
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 good 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.
If you want to review, verify, correct 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.
Complaint to a supervisory authority
If you want to lodge a complaint with a supervisory authority about our processing of your personal data, you can do so by contacting the Danish Data Protection Agency via their website, www.datatilsynet.dk.
You can read more about your rights in the Danish Data Protection Agency's guidelines on data subjects' rights, which is available at www.datatilsynet.dk (in Danish).
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: prosegurchangedpo@prettys.co.uk.
You have the right to make a complaint at any time to The Danish Data Protection Agency, the Danish supervisory authority for data protection issues.
Contact details:
You may contact us by phone, letter or e-mail using the following contact details:
Prettys Solicitors LLP
6th Floor, St Vincent House, Cutler Street, Ipswich, Suffolk, IP1 1UQ
United Kingdom