Candidate Privacy Policy

What is the purpose of this document?

rewardStyle, Inc. and its subsidiaries and affiliates (collectively, “rewardStyle”, “we”, “our” or “us”) are a “Data Controller”. This means that we are responsible for deciding how we hold and use Personal Information about you. This Candidate Privacy Notice explains how we collect, use, disclose and otherwise process Personal Information about our recruits and job applicants.

This Candidate Privacy Notice is not a contract and does not create any legal rights or obligations. This Candidate Privacy Notice also is not intended to replace other notices or disclosures we may provide to you in connection with your application for a job or eventual role in our organization, which will supersede any conflicting disclosures contained in this Candidate Privacy Notice.

WHAT IS PERSONAL INFORMATION?  

When we use the term “Personal Information” in this Candidate Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you within the context of you acting as a job applicant. It does not include aggregated or deidentified information that is maintained in a form that is not capable of being associated with or reasonably linked to you.

DATA PROTECTION PRINCIPLES  

We will follow data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant 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, per our data retention policy as mentioned in this document, for the purposes we have told you about.
• Kept securely.

THE KIND OF INFORMATION WE HOLD ABOUT YOU  

 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 resume, curriculum vitae, and cover letter.
• The information you have provided on our intake form, including name, title, address, telephone number, personal email address, gender, employment history, qualifications, and work interests.
• Any information you may provide to us during the interview and pre-hire processes.

We may also collect, store and use the following “Special Categories” of more sensitive Personal Information:

• Information about civil and criminal convictions and offenses.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?  

We collect Personal Information about candidates from the following sources:

• You, the candidate.
• From a variety of recruitment agencies depending on the position.
• Third-party applicant tracking systems
• Credit reference agency(ies) (for finance-handling roles), from which we collect the following categories of data: name, email address, date of birth, national insurance number, contact information, address history, and credit report.
• Background check provider(s) (for applicable roles), from which we collect the following categories of data: name, email address, date of birth, national insurance number, driver’s license number, address history, and background check report.
• Your named referees, from whom we collect the following categories of data: name, dates of employment, employment relationship, and work characteristics.
• From third party publicly accessible sources, such as LinkedIn, Indeed, and other social media networks where we may collect the following categories of data: name, dates of employment, job titles, employment history, work characteristics, data included on posts that you have posted or shared.

HOW WE WILL USE INFORMATION ABOUT YOU  AND LAWFUL BASIS FOR PROCESSING

 We will use the Personal Information we collect about you to:

• Assess your skills, qualifications, and suitability for the role.
• 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.

It is in our legitimate interest to decide whether to appoint you to the role 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 of employment with you.

Having received your intake form, resume/CV, and cover letter, 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 ask you to a phone screen and potentially a behavioral profile to assess 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 position. We will then check your references. If we decide to offer you the position, we will carry out a background check before confirming the role.

 
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 background 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.

INFORMATION ABOUT YOUR BACKGROUND CHECK
Once the offer has been accepted, we will begin our pre-hire process where we will conduct a background check to collect information about criminal convictions if applicable to your role. For finance-handling roles, will conduct a credit history check. We are entitled to carry out the steps in the pre-hire process for certain roles in order to satisfy ourselves that there is nothing in your criminal convictions, civil or credit history which makes you unsuitable for the position offered. For example, if the position requires a high degree of trust and integrity as a result of it involving or relating to customer accounts and customer or company funds, then we would request a basic disclosure of your criminal and credit record information.

 We have in place an appropriate policy document and safeguards which we may be required by law to maintain when processing such data.

AUTOMATED DECISION-MAKING  

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

DATA SHARING  

We will only share your Personal Information with third parties 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, if required by applicable law. We do not allow our third-party service providers to use your Personal Information for their own purposes, if required by applicable law. We only permit them to process your Personal Information for specified purposes and in accordance with our instructions, if required by applicable law.

DATA SECURITY  
We have put in place commercially reasonable security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized 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.

DATA RETENTION  

We will retain your information for a fixed period, typically on an annual basis for those requisitions closed or filled prior to January 1st of the preceding year. 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. We also retain your Personal Information to alert you of future job opportunities that may arise that you may want to consider. After this period, we will securely destroy your Personal Information in accordance with our data retention policy.

We have the right to delete personal information and materials you provided to us as part of your application process. We reserve the right to anonymize your personal information so it can no longer be associated with you, and to use such anonymous or de-identified data for any legitimate business purpose without further notice to you.    

If you are offered and accept employment, the Personal Information we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our Staff Privacy Notice.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION  (FOR JOB APPLICANTS LOCATED IN THE UK AND EU ONLY)

 Under certain circumstances, by law you 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 it.
• 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.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no valid 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 particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing 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 it.
• Request the transfer of your Personal Information to another party.

If you want to review, verify, correct or request erasure of your Personal Information, object to the processing of your Personal Information, or request that we transfer a copy of your Personal Information to another party, please submit a request to HRdatarequests@rewardstyle.com.There may be exceptions to these rights in certain circumstances and where you cannot exercise a right due to an exception, we will provide this explanation.

RIGHT TO WITHDRAW CONSENT  

When you apply for a role, you provide consent to us processing your Personal Information for the purposes of the recruitment exercise (if required by applicable law). You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact HRdatarequests@rewardstyle.com. 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 Personal Information securely.    

CHANGES TO THIS NOTICE AND QUESTIONS

We reserve the right to update this Candidate Privacy Notice at any time. If you want to see changes made to this Candidate Privacy Notice from time to time, we invite you to access this Candidate Privacy Notice to see the changes. If we make material changes or changes that will have an impact on you (e.g., when we start processing your personal data for purposes other than set out above), we will contact you prior to commencing that processing.

If you have any questions about this Candidate Privacy Notice or how we handle your Personal Information, please contact HRdatarequests@rewardstyle.com. If applicable, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, or your local supervisory authority.

Candidate Privacy Notice Last Updated: July 1, 2021