Legal | Applicant Privacy Notice

Applicant Privacy Notice

This notice provides you with information on how GeoComply Solutions Inc., together with its subsidiaries and affiliates (“we”, “us”, “our”)  processes your personal data in connection with your job application.

We may update this notice from time to time, for example if we implement new systems or processes that involve the use of personal information. We will inform you about such updates, as required by applicable law.

If your job application is successful, you will receive a separate privacy notice from us explaining how we deal with the personal data of our employees.

1. What types of data do we process

Depending on several criteria, including, but not limited to, the recruitment process in which you participate, your location and your preferences, we may need to process certain data about you. In general, this may include:

a)any data that you choose to provide to us or to our recruitment agents or consultants, including typically:

• your identification data (including, but not limited to,, your name, surnames, address, contact telephone, country from which you interact with us, signature etc.),
• academic and professional training data,
• employment details (profession, professional history, etc.),
• data on your professional and/or individual interests and preferences

b) results of your test assignments;

c) notes, feedback, and analysis about you from those taking part on our behalf in the interviews with you and other stages of your recruitment process (including analysis by our employees, recruitment agents and consultants);

d) references and other information obtained about you from persons you indicate as your referees, but only upon your permission to gather such information; and

e) any information relevant to your skills and suitability for the role applied for that is collected by us or our agents or consultants from publicly accessible sources, such as your profile on LinkedIn.com (to the extent allowed by your account privacy settings).

2. Information you should not provide to us

We do not generally require special categories of data as part of our recruitment process. The following information should not be provided, unless you would like to include them in your application at your own initiative and with explicit consent for processing during the recruitment:

a) race or ethnicity;

b) political opinions;

c) religious or philosophical beliefs;

d) trade union membership;

e) sexual orientation, gender identity or relationship status;

f) criminal convictions and offences;

g) health, including any medical condition.

If you require accommodation to be made in connection with a disability or other special needs, please let us know.

3. Purposes of processing

We may process your personal data for the following purposes:

a) to assess your skills, qualifications, and suitability for the role(s) you have applied for, and, upon your consent, any other roles that may be available in the future;

b) to make decisions about whether to enter into a contract of employment or other similar relationship with you, and about the terms of that contract;

c) to communicate with you about the recruitment process;

d) to keep records related to our recruitment processes;

e) to comply with legal or regulatory requirements;

f) to process your application and organize the recruitment process;

g) to comply with legal obligations and cooperate with regulators and law enforcement bodies

h) to establish, exercise or defend legal claims; and

i) for the purposes referred to in the list of legitimate interests in section 4.

When making decisions about the progress of your application, whether to make an offer of employment to you and on what terms, our policy is to consider only information that is directly relevant to assessing your skills, qualifications, and suitability for the role. We have a zero tolerance approach for discrimination.

You are under no obligation to provide us with the data we ask you for. However, if you do not provide your personal data, the recruitment process might be delayed or made impossible. We will inform you to the extent the provision of your personal data is mandatory under applicable law.

4. Legal basis of the processing

We may process the data on the basis of:

a) the need to perform our contract of employment with you or to undertake certain actions at your request, prior to entering into a contract with you;

b) the need to comply with legal obligations to which we are subject;

c) our prevailing legitimate interests; and

d) consent , if legally required under local law for the purposes outlined in section 3 above.

Our legitimate interests on which we may rely are as follows:

a) to run an efficient recruitment process and fill our vacancies with suitable candidates;

b) to promote diversity and inclusion (to the extent permitted by law); and

c) to achieve the purposes referred to in section 3.

5. Transfer of your personal data

To achieve the purposes set out above, we may transfer your personal data to the following categories of recipients:

a) Within the GeoComply Group. The entity which you are applying to is part of a wider group (the “Group“), which shares management, human resources, legal, compliance, finance and audit resources. As a result, we may transfer your personal data to, or otherwise allow access to such data by other entities within the Group, which may use, transfer, and process the data for the following purposes: to maintain and improve recruitment processes; to maintain IT systems; to monitor and ensure compliance with applicable laws, policies and procedures; to establish and defend our legal rights; and to respond to requests and legal demands from regulators and other authorities. Our Group comprises companies in a number of EEA and non-EEA countries, including Canada, USA and Vietnam. To obtain a full list of our corporate entities, please contact us using the details provided below in section 8.

b) Service providers assisting us in the development, performance and management of our recruitment processes. Service providers act as our processors and process your personal data under our instructions. The data processors are subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal information, and to process the personal information only as instructed.

c) Regulators, authorities, and other third parties. As necessary for the processing purposes described above, personal data may be transferred to regulators, courts, and other authorities, independent external advisors, directors within the Group, internal compliance and investigative teams, external advisers appointed to conduct internal investigations, other service providers used by us or other members of our Group (for example, providers of online collaboration and productivity solutions, business software, cloud computing providers, legal and corporate administration services).

Some of the recipients referred to above are located or process personal data in countries other than the country in which you are located. The level of data protection in such other countries may not be equivalent to that in your local jurisdiction. However, we only transfer your personal data if and when appropriate safeguards are in place.

6. Retention periods

Your personal data will not be kept in a form that allows you to be identified for any longer than we reasonably consider necessary for achieving the purposes for which it was collected or processed or than the period prescribed by the applicable laws.

Your personal data will, in any case, be retained until the expiration of the latest period provided for by law for bringing legal claims against us in connection with the recruitment process. This is so that we can show, for example, 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 the aforementioned time period, we will destroy your personal information in accordance with our data protection, data retention and data security policies.

If we wish to retain your personal information on file for the purposes of considering you for further opportunities that may arise in the future, we will seek your explicit consent to retain your personal information for a fixed period on that basis.

7. Your rights in connection with your personal data

Subject to applicable law, you may have the right to:

a) obtain confirmation as to whether and what kind of personal data we store about you and to request a copy of such data;

b) request rectification or erasure of your personal data;

c) request us to restrict the processing of your personal data;

d) object to the processing of your personal data;

e) if you have given us your consent to process your data for any purpose, you also have the right to withdraw your consent at any time

f) lodge a complaint with the data protection supervisory authority in your country (or, if different, in the country where the infringement took place).

8. Right to withdraw consent

If we seek your explicit consent to process your data for any purpose, you have the right to withdraw your consent for processing for that purpose at any time. However, please remember that withdrawing your consent will not affect the lawfulness of processing based on any consent provided prior to withdrawal. To withdraw your consent, please contact us using the details in section 9.

9. Our contact details

Please address your requests or questions concerning the processing of your personal data to: privacy@geocomply.com.

Last updated 06/27/2022