1.0    Recruitment privacy policy

Full Circle Holding BV and all its subsidiaries  is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during the recruitment process, in accordance with the General Data Protection Regulation (GDPR) and Equal Employment Opportunity (EEO) regulation and applies to all candidates.

This Privacy Notice is for information only; it is not a contractual agreement.

1.1      To who does this policy apply

This Statement applies to individuals who access and use our recruitment platform, either online (website) through a mobile (app).



2.0    What information do we collect?

In connection with your application for work with us, we will 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/email;

• Any information you provide to us during an interview; and

• Information you provide in relation to your right to work documentation.

We may also collect, store and use the following “special categories” of more sensitive personal information:

• Information about your criminal record.

• Information about previous jobs and performance



We collect this personal information from the following sources:

• You, the candidate;

• Recruitment agencies;

• Search consultants;

• Our employment background check, whether done by the company or through third parties

• Our credit reference agency;

• Your named referees and/ or referrals; and

• Data from third party publicly accessible sources. For example, SRA and CILEx professional memberships, LinkedIn, Github and others.



3.0    Why do we process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check your eligibility to work in the country your apply for before employment starts.

 We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from you allows us to manage the recruitment process, assess and confirm your suitability for employment and decide to whom to offer a job. We may also need to process data from you to respond to and defend against legal claims.

We process health information if we need to make reasonable adjustments to the recruitment process for you. This is to carry out our obligations and exercise specific rights in relation to employment. This information is not requested or administrated in any of the standard defined recruitment steps. We ask candidates specifically not to share any medical information unless it is relevant for the recruitment process, location of the interview or for potential employment.

 We are entitled 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. We use a third party to do this on our behalf and may receive a copy of their report if you have consented for us to do so.

 We will not use your data for any purpose other than the recruitment exercise.



4.0    Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, approvers in the recruitment, offering or hiring process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties. We will make an exception for third parties advising us either in recruitment or those who contribute to the recruitment process, like assessment companies.  If and when your application is successful and we make you an offer of employment, we can then share your data with former employers to obtain references for you, our employment background check provider to obtain necessary background checks, including a criminal record check and our credit reference agency. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.

 We do not envisage transferring the personal information we collect about you outside the EU.





5.0    How do we protect data?

We take the security of your data seriously. 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.

 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.



6.0    For how long do we keep data?

If your application for employment is unsuccessful, we will hold your data on file for 6 months after the end of the relevant recruitment process. After this period, we will securely destroy your personal information in accordance with our data retention policy.

You will automatically be informed about the deletion 1 month before and you will be given the opportunity to consent to storing your data for another period of 6 months if you wish to retain your personal information on file.

 If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your (electronic) personnel file. The periods for which your data will be held will be provided to you in a new privacy notice.

6.1    Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;

• require us to change incorrect or incomplete data;

• require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;

• object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing; and

• ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.

 If you would like to exercise any of these rights, please contact either a member of the HR team.

6.2      Consent

Upon applying to one of our vacancies you will be asked to consent with processing your personal data. Also when you are referred by of our employees or an agency. Without this explicit consent we will delete your data automatically.



7.0    Change/ deletion of personal data

At any time you can change or delete your data. For you convenience this is an automated process that will be effective within a day. Please note that any change and/or deletion of your personal data or your profile may impact the recruitment process as we might no longer be able to execute upon our process.

7.1      What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

7.2      Automated decision-making

Recruitment processes are not based solely on automated decision-making.



8.0    Data storage

Your data will be stored in the European Union only.  However the data will accessible through a recruitment system for authorized users worldwide.

9.0    Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time.