Smart Heads Europe Ltd. Privacy Notice 

Smart Heads Europe Ltd., located in the United Kingdom (further named the “Company”) is strongly committed to protecting the privacy of all job applicants who apply for a position at the company (collectively, “you” or “Applicant”).  The Company has implemented the below to ensure all the Personal Data you provide is protected.

Personal Data is the information you provide and we use for purposes of your application to work at the Company, that either identifies you or permits you to be identified.

 

Identification of Data Controller 

The Company data controller of your Personal Data is located in the United Kingdom. You may identify data controller for your Personal Data by contacting us via [email protected]  or find out more on our website.

 

The Information the Company Collects 

The information collected by the Company may include, among other things, name; address; contact details including email address and telephone number; details of your qualifications, skills, experience and employment history; information about your current level of remuneration, including benefit entitlements; social security number or other national identification number; whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process; your entitlement to work in the country in which the position is located; and other information included by you in your resume or curriculum vitae. We collect this information from you and in certain instances from third parties (e.g., information gathered during a background check or ongoing compliance screening against publically available watch and sanctions lists, information gathered from social media platforms, recruitment vendors, and other publicly available sources).

The Company does not collect your Sensitive Personal Data unless we are required or permitted to do so by applicable law, or you have, in accordance with applicable law, provided your explicit consent to the collection and processing of your sensitive personal data.  Sensitive Personal Data means information relation toracial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and biometric data.

Smart Heads Europe Ltd. uses cookies on our Website (the “Service”). By using the Service, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

 

What are cookies

Smart Heads Europe Ltd. uses cookies and similar technologies such as tags and pixels (which we will refer to collectively as “Cookies”). Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognise you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies.

 

We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:

Essential cookies 

We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.

Third- party cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

What are your choices regarding cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
The Way the Company Uses the Personal Data 

The Personal Data you provide will become part of the Company’s master databases and paper files, maintained for purposes related to your application for employment with the Company including, processing your application to assess whether you are suited for a specific position, compliance with legal and regulatory requirements, and to conduct ongoing compliance screening against publically available watch and sanctions lists.

The above processing may be performed both electronically and in hard copies.

 

The Way the Company Secures the Personal Data

The Company maintains appropriate technical and organisational measures designed to protect your Personal Data against loss or accidental, unlawful or unauthorised, alteration, access, disclosure or use.

Your Personal Data will not be stored for longer than necessary for the purposes for which they were collected or as required under applicable retention policies and/or in accordance with applicable law.  Our retention practices reflect local statute of limitation periods and national statutory obligations of the Company.This retention period may be extended if the Company is required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required by applicable law.

 

Disclosing Personal Data to a Third Party

The recipients of your personal data within the Company may include the Legal, Human Resources, Finance and Information Technology departments.

The Company may share your Personal Data with third parties as necessary to achieve the purposes outlined in this notice. Further, the Company may be required to disclose Personal Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

The Company requires that such third parties keep your Personal Data confidential (unless otherwise required by law) and that they only use your Personal Data in furtherance of the specific purpose for which it was disclosed. You are responsible for any additional permissions you choose to grant to service providers for other services.

Please note that the Company and its third party service providers may use your Personal Data in an anonymized format (i.e., in a form in which your identity cannot be determined) for other purposes not specified above, including in the development and testing of products and services.

To enable us to effectively share your Personal Data with third parties as described in this Privacy Notice, we ask you to provide your consent at the end of this Notice to the extent required by your local data privacy laws.

 

How to Contact Us

Should you have questions about the Personal Data about you that the Company holds and for all communications, queries and requests that are related to data protection issues, you may contact the Company’s Privacy Manager directly via:

 

Smart Heads Europe Ltd., 24 Holborn Viaduct, London EC 1A 2BN, United Kingdom

Email us: [email protected]

 

 

 

Changes to This Privacy Notice

This notice may be amended from time to time to ensure consistency and compliance with changes in the statutory requirements.  The current version can be obtained by contacting the Company’s website or our Data Protection Manager by using the contact information presented above.

Smart Heads Europe Ltd. EEA GDPR Amendment 

(valid on May 25th, 2018)

 

If you are a resident of the European Economic Area (“EEA”), the following additional EEA-specific provisions apply to the Company’s processing of your Personal Data. For such data subjects, the provisions of this EEA GDPR Amendment prevail over any conflicting provisions in the Smart Heads Ltd. Privacy Notice.

 

Relevant Data Controller

Smart Heads Europe located in the EEA is collecting Personal Data.

The Company legal entity that is the responsible data controller of your Personal Data is the Company entity located in the jurisdiction where you reside and with which you interacted. You may identify the relevant Company entity acting as data controller for your Personal Data by contacting us via [email protected]  or visiting our websites for further contact details.

 

The Information the Company Collects 

The Personal Data that may be collected and further Processed by the Company includes the following data categories:

  • Personal identification data, such as your name, home address, date of birth, gender, work- related photographs, and home phone number;
  • Government-issued identification numbers, such as national ID and social security number;
  • Immigration, right-to-work and residence status;
  • Family and emergency contact details;
  • Job-related information, such as level of service, details of your qualifications, skills, work location, experience, work record and employment history, information about your current level of remuneration, including benefits entitlements, vacation absences, your CV and contract data;
  • Educational and training information, such as your educational awards, certificates and licenses, vocational records and in-house training attendance;
  • Health related information, such as whether or not you have a disability for which Smart Heads Europe Ltd. needs to make reasonable adjustments during the recruitment process;
  • Recruitment and performance-related data, such as professional and personal reference contacts, objectives, ratings, comments, feedback results, career history, eligibility for re-hire, work equipment, career and succession planning, skills and competencies and other work-related qualifications.

We collect this information from you and in certain instances from third parties (e.g., information gathered during a background check or ongoing compliance screening against publically available watch and sanctions lists, information gathered from social media platforms, recruitment vendors, and other publicly available sources).

Smart Heads Europe Ltd. does not collect Sensitive Personal Data unless we are required or permitted to do so by applicable law, or you have, in accordance with applicable law, provided your explicit consent to the collection and processing of such information.

 

Legal Bases for Use of Your Personal Data 

The legal bases for which we collect, use, transfer, disclose or otherwise process your Personal Data include (i) your consent and (ii) any applicable legal requirement to which the Company is subject. The corresponding purposes for which we process your Personal Data are systematically included in the “The Way the Company Uses the Personal Data” section in the Privacy Notice above.

 

Disclosures and International Data Transfers 

Due to the global nature of the Company’s business, the Company may disclose your Personal Data to the following recipients:

  • Other Company entities, joint ventures, subcontractors, vendors or suppliers who perform services on our behalf, as well as legal, accounting and other professional services firms;
  • A newly formed or acquiring organization if the Company is involved in a merger, sale or a transfer of some or all of its business; or
  • Any recipient, where the Company is required to do so, such as by court order or by law.

If you are a resident of the European Economic Area, we may transfer your Personal Data to countries that have not been found by the European Commission to provide adequate protection. For any such transfers, the Company has put in place a data transfer mechanism to ensure that your Personal Data receives an adequate level of protection (including, for example, the EU-U.S. and Swiss-U.S. Privacy Shield). For the avoidance of doubt, the Company will not rely solely on your consent for such data transfers if you are an EU resident. For further information about the Company’s international data transfer practices, and to consult the said contractual measures or the relevant data transfer mechanism, please contact us using the contact details in the “How to Contact Us” section above.

 

Your Rights 

You have certain rights with regard to the processing of your Personal Data by the Company, including: (i) the right to access your Personal Data; (ii) the right to obtain correction of your Personal Data which is incomplete, inaccurate or outdated; (iii) the right to request the transmission to you of your Personal Data you have provided to us or to another company, (iv) the right to object to any uses or disclosures of your Personal Data, (v) the right to withdraw your consent in relation to our processing of your Personal Data if such processing was based on your consent (which will only affect processing after withdrawal), (vi) the right to request deletion of your Personal Data and (vii) the right to request that we restrict processing of your Personal Data.

You may exercise these rights free of charge. However, the Company may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, the Company may refuse to act or may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation, or infringe applicable law. In addition, prior to acting upon any of rights, the Company takes reasonable steps to verify your identity. In all cases, you have a right to file a complaint with a Supervisory Authority.

 

Changes to This Privacy Notice

This Privacy Notice may be amended from time to time to ensure consistency and compliance with changes inapplicable law. We will notify you once an updated version of this notice becomes available.