GROUP RECRUITMENT PRIVACY NOTICE

Introduction

1. Your privacy is important to us and we are committed to safeguarding the privacy of our job candidates. 
2. This Group Recruitment Privacy Notice lets you know how we collect and use your personal data during our recruiting process in compliance with applicable data protection laws, including the European Union General Data Protection Regulation 2016 (hereafter referred to as the “GDPR”) and the Data Protection Act 2017 (hereafter referred to as the “DPA”).
3. JurisTax is made up of different legal entities, details of which can be found here. In this notice, “JurisTax” refers to JurisTax Holdings Ltd, including its subsidiaries and affiliates (also referred to as “we”, “us” and “our”). 
4. This notice describes the broadest potential use of personal data; we may make less use of your personal data than it is described in this Notice.

 

2. Collecting your personal data

1. The type of personal data we collect and process will depend on the purpose for which it is collected. We will only collect and process data that we need for that purpose.   
2. We may collect your personal data in connection with your recruitment in the following ways:
   • Your personal data is provided to us directly by you for e.g. when you give us your CV or submit your CV as part of the online application, information contained in your passport or other identity documents, or collected through interviews or other forms of assessment.
   • Your personal data is provided to us by a third party, for e.g. professional recruiting firms. and references supplied by your previous employers, and
   • Your personal data is collected from publicly accessible sources, such as LinkedIn, etc. 
3. We are likely to collect, process and maintain your personal data including:

Categories of personal data	Details
Contact details	First name, surname, physical address, email address, office phone number, cell phone number.
Individual details	Sex (male/female), nationality, date of birth, age, language, marital status, photograph.
Educational and professional background	CV/ resumé, academic and professional qualifications, employment history, reference letters and interview notes, secondary employment and volunteering information.
Identification details	National identity card number, passport number.
Financial information	Information about your current level of remuneration, including benefit entitlements.
Special categories of personal data	Certificate of character containing information about criminal convictions/ allegations and offences (only for vetting purposes, where permissible and in accordance with applicable law). Data concerning your health and any disability.
Other	Information you choose to share with us such as your hobbies and social preferences, your Linkedin ID.

1. Sensitive data that are collected by JurisTax qualifies as special categories of personal data. This information, when collected, is generally done so on a voluntary, consensual basis, and job candidates are not required to provide this information, unless it is necessary for us to collect such information to comply with our legal obligations or exercising our specific rights.
2. For instance, we may request or require your certificate of character in connection with our recruiting efforts, for the purposes elaborated in Section 3. You may also choose to provide us with information on whether you have a disability and would like us to consider any accommodation.
3. To the extent data you provide contains details of your racial or ethnic origin, political opinions or beliefs, religious beliefs, membership in a trade union or political party, physical or mental health or condition, sexual orientation, commission or alleged commission of an offence or related proceedings, job evaluations or educational records, you expressly authorise JurisTax to handle such details as specified in this notice.

 

3. Using your personal data

1. JurisTax will only use your personal data for the purpose for which it was collected or agreed with you. If you are hired by JurisTax, we may collect other necessary personal data in connection with your employment as described in our Group Employee Privacy Notice, a copy of which will be provided when you are on-boarded as an employee if applicable.
2. We have set out below the legal basis of processing for each purpose. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. 

Purpose of processing	Legal basis of processing
As required for the recruitment process at JurisTax: ·        for communicating with you, ·        to analyse your qualifications and references, ·        to set out your job conditions, ·        to know whether there are previous criminal convictions recorded against you, and ·        to cater for special accommodations in case you provide us with additional data about your health condition.	·        The processing is necessary to perform a contract or to take steps at your request, before entering a contract, namely your contract of employment. ·        For our legitimate interests namely for the proper administration of our business and to ensure appropriate job candidates are being recruited. ·        The processing is necessary for the assessment of the working capacity of an employee. ·        The processing is necessary for the purpose of carrying out our obligations and of exercising specific rights in relation to employment, for e.g. under the Worker’s Rights Act or the Equal Opportunities Act.
Storing your CV and contact details for the purpose of contacting you in the event there are future job opportunities	·        Consent

1. Please contact the Group Data Protection Officer (hereafter referred to as the “Group DPO”) if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been mentioned below.

4. Voluntary disclosure of your personal data

1. Your provision of personal data in connection with your job application and recruitment is voluntary, and you determine the extent of data you provide to us.
2. Please note that if you decide not to provide your personal data, it may affect our ability to consider you for employment.

5. Who has access to your personal data?

1. Access to your personal data within JurisTax 
   • Our employees who may have access to your personal data are required to keep that data confidential. 
   • We may employ security procedures at our facilities and on our computer systems to monitor and maintain security, including the use of CCTV. Any monitoring of our facilities, systems or assets is performed in accordance with applicable law.
2. Access to your personal data by third parties
   • Except as otherwise stated in this notice or as required for legal or regulatory purposes, we treat your personal data as confidential and will not disclose it to third parties without your consent. We do not share personal data you provide to us for recruitment purposes with any service providers or other third parties, unless your application for employment is successful and JurisTax makes you an offer of employment.
   • We may however share your personal data with public and government authorities, as required by applicable laws and regulations, for national security and/or law enforcement purposes.
   • For more details, please contact the Group DPO on dpo@juristax.com.

6. Security of your personal data

1. We have put in place appropriate security measures to prevent your personal data from being subject to any accidental or unlawful destruction, loss, alteration, and any unauthorised disclosure or access. 
2. We have also put in place procedures to deal with any suspected data security breach and will notify you and the Data Protection Office of a suspected breach where we are legally required to do so.

7. Your data protection rights

1. Under applicable data protection laws, you have the right to erase, access, rectify, restrict the processing of, and object to the processing of your personal data. To the extent that the legal basis for our processing of your personal data is consent, you also have the right to withdraw that consent at any time. You may also exercise a right to data portability as defined under the GDPR.
2. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
3. For further details on all your data protection rights, please refer to Section 9 of our Group Website Privacy Notice.

8. Retention of your personal data

1. Where we collect and or process your personal data for a specific purpose, we will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons. To the extent permitted or required by law, we may delete your personal data at any time. Accordingly, you should retain your own copy of any data you submit to us.
2. If your application for employment is unsuccessful, JurisTax may, with your consent, retain your personal data on file for six months after the end of the relevant recruitment process in order to consider you for other job opportunities. At the end of that period, or once you withdraw your consent, your personal data is deleted or destroyed. 
3. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your personal data will be held will be provided to you in our Group Employee Privacy Notice.
4. During your recruitment process, you may submit requests to access or correct your personal data, or any other requests concerning your personal data to the Group DPO.

9. Your responsibilities

1. You are responsible for the data you provide or make available to us, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the data provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party, does not contain malicious code; and is not otherwise legally actionable.
2. Further, if you provide any data concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for us to collect and use that data as described in this notice.

10. Cross border transfer

1. As an organisation headquartered in Mauritius, we have offices in Rwanda and Dubai. Therefore, your personal data may be transferred, accessed and stored globally by JurisTax members as necessary for the uses and disclosures stated above in accordance with this notice. We have developed global data security practices designed to ensure that your personal data is appropriately protected.
2. Where such cross-border recipients, including our subsidiaries and affiliates, are found abroad, we have entered into and executed an agreement for the international transfer of personal data (hereafter “Cross-border Agreement”) with them which allows for the processing of your personal data and which also incorporates the European Union Model Clauses requirements for transfers of your personal data.

 

11. Dispute resolution

1. If you have any complaints regarding our compliance with this notice, you should contact the Group DPO. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your personal data in accordance with this notice.
2. If you believe that we have not handled your request in an appropriate manner, then you have the right to lodge a complaint with the Data Protection Office in Mauritius.

 

12. General

1. We may update this notice from time to time.  The latest version will be available on our website. Please check this page regularly to keep up to date. 
2. If you have any questions or concerns about this notice or its application, or if you believe your personal data has been used in a way that is not consistent with this notice or your specified preferences, please contact the Group DPO on dpo@juristax.com.