IRP Candidates PRIVACY NOTICE

 

Last updated: November 2, 2022

 

IRP Nexus Group Ltd. (“IRP”, “we” or “us”) has prepared this IRP Candidates Privacy Notice (“Notice”) to be provided to IRP’s Candidates. This Notice describes how we collect, process and use Personal Data regarding our job candidates and applicants (“Candidates”, “you” or “your”).

Please read this Notice carefully, so you can understand our practices and your rights in relation to Personal Data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Please note that this is a master Notice and some of its provisions only apply to individuals in certain jurisdictions. Nothing in this Notice is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. If you do not agree to this Notice, please avoid providing us with your Personal Data.

1. What categories of Personal Data does IRP collect about me?

IRP will collect, process and use the following categories of Personal Data about you:

• Identification data, such as your full name, date and place of birth, military and reserves status, social security number, government-issued identification information (e.g., driver’s license, passport), photographs, or other similar identifiers;
• Contact details, such as your home address, email address and telephone number;
• Professional experience information such as as CV information, cover letter, education, training history, port-folio, and any other relevant information that you decide to share with us;
• Performance information, such as candidate evaluation metrics, interview notes and recordings, performance evaluations and feedback recommendations;
• Nationality and immigration status, and other information such as residency and work permit status, that would allow us to verify your employment eligibility;
• CCTV footage and other information obtained through electronic means such as swipecard records;
• Other data you provide to us, such as your feedback and survey responses where you choose to identify yourself.

together “Candidates Data”.

2. Why does IRP need to Collect and Process my Candidates Data?

We collect and use this Candidates Data for a variety of reasons linked to your employment described below (the “Processing Purposes”) along with examples of some of the Candidates Data used for each of the Processing Purposes:

• Administering our workforce including evaluating applicants, assessing eligibility for employment, conducting background checks (to the maximum extent permitted by law), managing work activities, which involves the processing of identification data, contact details, and professional experience information;
• Checking you are legally entitled to work in the relevant country, which involves the processing of identification data, contact details, and nationality and immigration status;
• Complying with applicable laws and employment-related requirements along with the administration of those requirements and employment and immigration laws which involves the processing of identification data, contact details, nationality and immigration status and performance information; and
• Monitoring and securing our offices and premises, including through the use of CCTV footage and building access information;

3. If you fail to provide Personal Information

If you fail to provide the information requested, we may not be able to perform our contractual obligations with you or we may be prevented from complying with our legal obligations. In such circumstances, we may not be able to complete your recruitment.

4. How do we collect this Personal Information?

In most cases, IRP collects Personal Data directly from you. At times, IRP may also receive Personal Data publicly available sources, a benefits provider, or other service providers involved in the Processing Purposes. For example, we typically collect Candidates Data:

• during the recruitment process; In addition, we may receive Personal Data about you from non-publicly available sources.
• recruitment consultants; and
• former employers.

5. How might IRP share my Personal Data?

IRP may transfer Personal Data to third parties, including to entities within and outside the IRP group located in any jurisdictions where IRP group entities are located, for the Processing Purposes as follows:

• Regulators, authorities, and other third parties. As necessary for the Processing Purposes described above, we will share your Personal Data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
• Service providers. As necessary for the Processing Purposes described above, Personal Data may be shared with one or more third parties, whether affiliated or unaffiliated, to process Personal Data under appropriate instructions (“Service Providers”).
• Professional advisors. We may share Candidates Data with our professional advisors such as lawyers and accountants where doing so is necessary to facilitate the services they render to us.

6. How long will IRP keep My Personal Data for?

We will retain your Personal Data for as long as necessary to fulfil the Processing Purposes and comply with our legal obligations. To determine the appropriate retention period for Personal Data, we consider the amount, origin nature, and sensitivity of the confidential data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable local legal requirements as well candidates interest in privacy.

7. Additional information regarding transfers of Personal Data

• Storage: The Personal Data stored in Comeet’s internal server, located in Israel, in the company local server in Israel, and on Microsoft Exchange 365 servers.
• External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When IRP engages in such transfers of Personal Information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. IRP also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.

 

8. What rights do I have in respect of my Personal Data?

Under certain circumstances specified by law, you may 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
• Request correction/rectification of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you
• 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 situation that 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
• Request the transfer of your Personal Information to another party (data portability).

9. Can IRP update this Notice?

We reserve the right to update this Notice at any time, and we will provide you with a new Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.

10. Contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@irpsystems.com.