What is the purpose of this document?
This Privacy Information Notice applies across The Change Group International (Cyprus) Ltd, or any of its subsidiaries or holding companies from time to time and any subsidiary of any holding company from time to time). 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 Law Providing for the Protection of Natural Persons With Regard to the Processing of Personal Data and for the Free Movement of Such Data of 2018 (Law 125(I)/2018) (as amended), which has implemented the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “EU Regulation”) and the EU Regulation (together the “Cyprus GDPR”). We are a "data controller".
Data protection principles
We will comply with Cyprus GDPR and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid specified, explicit and legitimate purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant and adequate 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, i.e. in relation to the recruitment exercise.
- Kept securely and protected against unauthorised or unlawful processing and against loss or destruction or damage using appropriate technical and organisational measures.
The kind of information we hold about you
In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information that you provide on our application form, including amongst others, name, title, address, telephone number, personal email address, date of birth, eligibility to work in Cyprus, employment history, qualifications.
- Any information you provide to us during an interview.
- Any information that you provide to us as part of the application process including any test results.
We may also collect, store and use the following "special categories" of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences, where any applicable law allows us to do so.
How is your personal information collected?
We may collect personal information about candidates from the following sources:
- You, the candidate, either directly or via an online job website (for example, Indeed).
- A recruitment agency, from which we may collect the following categories of data: name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications.
- Your named referees.
- Google search.
How we will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role applied for.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
Where you have provided us with your personal data on a speculative basis, rather than in order 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.
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.
It is in our legitimate interests to use your personal data in the ways listed above in order to decide whether to appoint you to the role or notify you of any relevant vacancies since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract with you.
Having received your CV and covering letter and/or your application form and the results from any tests, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we may then take up references and/or carry out a criminal record and/or carry out any other checks before confirming your appointment (where any applicable law allows us to do so).
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.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are required to ask you to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role (where any applicable law allows us to do so). In particular:
- 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 any applicable law to maintain when processing such data.
Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in certain circumstances. 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 external job sites, including Indeed and other companies within our 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.
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?
We will retain your personal information for a period of 6 months after we have communicated to you our decision about whether to appoint you to the role. 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 destroy 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 a period of six months from receipt of the information from you. 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 destroy your data in accordance with our data retention policy.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, pursuant to Cyprus GDPR you have the right to:
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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.
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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.
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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).
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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.
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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. To that effect, we shall no longer process your personal information unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
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Request the transfer of your personal information to another party (i.e. you have the right to receive your personal information in a structured, commonly used and machine-readable format, in order to be transferred to another data controller).
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.
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: changegroupdpo@prettys.co.uk.
We are committed to working with you in order to obtain a fair solution of any bona fide concern, grievance or complaint with respect to our data privacy management procedures and practices.
Also, you have the right to make your complaint regarding our data processing activities to the Office of the Commissioner for Personal Data Protection in the below contact details:
Address: Kypranoros 15, Nicosia 1061, Cyprus
Postal address: P.O.Box 23378, 1682 Nicosia, Cyprus
Telephone: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
Website: http://www.dataprotection.gov.cy
