Candidate Privacy Notice

our privacy is important to Globalization Partners, Inc. and its subsidiaries and affiliates (“Globalization Partners”, “our”, “we,” or “us”). This Candidate Privacy Notice (“Privacy Notice”) explains how we collect, use, share and protect the personal data or personal information (“Personal Information”) of applicants during the application process. Personal Information means any information that directly identifies an individual or that makes an individual identifiable when combined with other information, such as, your name, address, membership and/or student number, NI number, Passport number, Tax ID, qualifications, date of birth, photos. Globalization Partners is the controller for your Personal Information. In case of a conflict between this Privacy Notice and applicable law, applicable law will govern.

By submitting your Personal Information to us, you acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of your Personal Information as set out herein.
• Your Personal Information may be transferred and processed worldwide, including in countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice
• You are not required to provide any requested information to us, but your failure to do so may result in our not being able to continue your candidacy for the job for which you have applied.
• All of your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.
• This Privacy Notice does not form part of any contract of employment offered to candidates hired by Globalization Partners.

The types of Personal Information that we request from you and the ways that we process it are determined by the requirements of the country in which the role you apply for is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of Personal Information we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located.

We usually collect Personal Information directly from you when you apply for a role with us, such as your name, address, contact information, photographs and videos, work and educational history, achievements, identity documents, and test results. If you receive an offer from us, we may then conduct a background check and, to the extent permitted by applicable law, we may also collect data related to criminal offences and proceedings, as well as regarding sanctions status, by screening against external, publicly available databases and global sanctions lists. We also collect similar Personal Information about you from third parties, such as professional recruiting firms, your references, prior employers, Globalization Partners’ employees with whom you have interviewed or who recommended your candidacy, and, to the extent permitted by applicable law, employment background check providers. We may also collect Personal Information about you online to the extent that you have chosen to make this information publicly available. For example, we may find your profile on professional social media websites (such as LinkedIn and/or XING), and contact you about suitable roles.

Sensitive Personal Information is a subset of Personal Information that includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, and other categories as prescribed by law. We may collect sensitive Personal Information about a candidate to the extent permitted to do so by applicable laws (e.g., U.S. equal opportunity laws) and to support our efforts to create an inclusive and diverse work environment. We may also collect sensitive Personal Information to the extent that a candidate chooses, without being asked, to voluntarily disclose it during the recruiting process. Under limited circumstances and to the extent permitted by applicable law, we may also collect sensitive personal information relating to health and medical characteristics, such as status of infection, test results, and vaccination status, to address our public health and workplace safety obligations and to protect the Firm and its employees, clients, and third parties.

You are under no statutory or contractual obligation to provide Personal Information to us during the application process. However, if you do not provide us with your Personal Information we will not be able to process your application properly or at all.

We collect and use your Personal Information for legitimate human resources and business management reasons, including:

• identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
• maintaining records in relation to recruiting and hiring;
• ensuring compliance with legal requirements, including those relating to public health and workplace safety;
• fostering our diversity and inclusion programs and practices;
• conducting background checks, including, to the extent permitted by applicable law, and if you receive an offer from us, criminal history checks;
• protecting our legal rights to the extent authorized or permitted by law; and
• protecting the workplace and communicating with medical professionals, law enforcement, or other public authorities in the event of an emergency or public health event, such as when the health or safety of you or one or more individuals may be endangered, including, to the extent permitted by applicable law, sharing data about the status of an infection, test results, and vaccination status.

We may also use your Personal Information for Globalization Partners’ analytics purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and augment our ability to attract successful candidates.

Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. In order to comply with data protection laws, we need a lawful basis to process your Personal Information. The tables below describe the ways in which we use your Personal Information and the legal bases we rely on to do so. Where appropriate we have also set out our legitimate interests in processing your Personal Information. Table A covers the Personal Information we collect and hold up to the shortlisting stage of the recruitment process. By the term shortlisting we mean any part of the recruitment process which takes place up to the point where a conditional offer of employment is made. Table B covers the Personal Information we collect and hold before making a final decision to recruit.

Table A: Personal Information collected and used up to and including the shortlisting stage

PURPOSE AND/OR ACTIVITY	TYPE OF DATA	LEGAL BASIS FOR PROCESSING
To contact you to progress your application, arrange interviews and inform you of the outcome. To inform the relevant manager or department of your application.	Identity Data, Contact Data	Legitimate interest: to carry out a fair recruitment process, arrange interviews and to inform you of the outcome at each stage.
To make an informed decision as to whether to shortlist you for interview, or make an offer of employment to you.	Career Data, Education Data, Social Media Data	Legitimate interest: to carry out a fair recruitment process and to assess your suitability for employment by making an informed decision to shortlist for interview and (if relevant) to recruit.
To help monitor the effectiveness of our equality, diversity and inclusion policy.	Equal Opportunities Data	Consent: to be obtained at the recruitment stage for processing equal opportunities data.
To carry out a fair recruitment process.	Identity Data, Reference Data	Legitimate interest: to carry out a fair recruitment process and to assess your suitability for employment by making an informed decision to shortlist for interview and (if relevant) to recruit.
To determine whether reasonable adjustments are required to the recruitment process because of a disability you may have.	Identity Data, Health Data	Legal obligation: To comply with our legal obligations.
Anonymisation of Personal Information for the onward activities of Management Information and Business Intelligence.	All Personal Information	Legitimate Interest of Globalization Partners for business improvement and intelligence purposes.
Internal Audit.	A sample of all Personal Information	Legitimate Interests: where we have a legitimate interest in auditing our internal processes and procedures to ensure that we are complying with applicable laws and internal and managing risk appropriately.

Table B: Personal Information collected and used before making a final decision to recruit

PURPOSE AND/OR ACTIVITY	TYPE OF DATA	LEGAL BASIS FOR PROCESSING
To obtain the relevant reference about you in order to verify the information you have provided to us.	Identity Data, Education Data, Reference Data	Performance of a Contract – to enter into a potential employment contract with you.
To carry out right to work checks.	Identity Data, Nationality and Immigration Data	Legal obligations: to check your eligibility to work in the location you are applying to.
To make an informed recruitment decision	Identity Data, Criminal Offence Data, Background Checks Data, Sanctions Data	Legitimate interest: to carry out a fair recruitment process, maintain employment records and enter into/perform the employment contract; to assess your suitability for employment by making an informed decision to recruit. Performance of a contract: to perform precontractual measures related to establishing our employment relationship.

Where the information we process is special category data such as your health data, the additional bases for processing that we rely on are:

Where you have provided Globalization Partners with your explicit consent to the processing.

Where processing is necessary in relation to carrying out our legal obligations and exercising our legal rights as your employer.

Where processing is necessary for the establishment, exercise, or defense of legal claims.

If you receive an offer from us, we may conduct a background check on you or instruct a third party to do so on our behalf. Background screening will only be done where permitted by the law applicable to the location where the position is located and to the extent necessary and proportionate to the role that you are being offered. A background check will only involve criminal background data, as well as screening against global sanctions lists, to the extent permitted by law. Our legal basis for background screening is our need to perform precontractual measures related to establishing our employment relationship, as well as our legitimate interest to assess your suitability for employment by making an informed decision to recruit. If a background screening is required, you may be contacted by a third-party background screening service provider to request authorization for the release of your information, and at that time you will be provided with further information about the process and what personal data it might involve.

Your Personal Information may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the Globalization Partners global organization. Individuals performing administrative functions and IT personnel within Globalization Partners may also have limited access to your Personal Information to the extent necessary to perform their jobs. In some countries, you may have fewer rights under local law than you do in your country of residence, but we have put in place legal mechanisms designed to ensure adequate data protection for your Personal Information when it is processed by Globalization Partners subsidiaries and affiliates within the Globalization Partners global organization and by Globalization Partners’ service providers, including the transfer of your Personal Information to countries other than the one in which you reside.

We use third-party service providers to provide a recruiting software system. We also share your Personal Information with other third-party service providers that may assist us in identifying and recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.

Except to the extent necessary to accomplish the Globalization Partners uses and purposes described in this Privacy Notice, we do not disclose your Personal Information to third parties. We also prohibit our service providers from using your Personal Information for non-Globalization Partners purposes. We do not otherwise share or sell your Personal Information to third parties.

We maintain processes designed to help ensure that any processing of Personal Information by third-party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your Personal Information in compliance with applicable law.

Your Personal Information may be transferred to countries outside the European Economic Area (EEA) or the United Kingdom (UK). For example, your Personal Information may be shared with one of our overseas offices if necessary or where you provide Globalization Partners with an international referee. Where data is transferred outside of the EEA and the UK, it is done so on the basis of appropriate safeguards, for example, as applicable, the EU Standard Contractual Clauses and the UK Addendum to the EU Standard Contractual Clauses issued by the UK Information Commissioner’s Office under s.119A(1) of the UK Data Protection Act 2018.

In addition, we may disclose or transfer your Personal Information in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

We have appropriate security measures in place to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your Personal Information to those who have a genuine business need to know it. Those processing your Personal Information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

In accordance with applicable law, you may have one or more of the following rights:

• right to know, access and request information about the Personal Information we hold about you, including the details of how we use that information and who we share it with;
• right to request a copy of the Personal Information that we hold about you;
• right to amend, correct or rectify your Personal Information if any of the information held about you is incorrect or out of date;
• right to portability of your Personal Information;
• right to request deletion of your Personal Information;
• right to demand that we cease the processing of your Personal Information or that we restrict the processing of your Personal Information;
• right to withdraw your consent to the processing of your Personal Information, to the extent our processing relies on your consent as the lawful basis for processing. This right may not apply if there are other legal justifications to continue processing or we need to retain certain Personal Information where required or permitted under applicable law; and/or
• right to provide us with instructions as to the processing of your Personal Information in case of death.

In addition, and where granted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.

We keep Personal Information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed.

If you accept an offer of employment with us, any relevant Personal Information collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements and with the privacy notice applicable to Globalization Partners employees, which will be provided during the on-boarding process.

If we do not employ you, we may nevertheless continue to retain and use your Personal Information for a period of time (which may vary depending on the country) for system administration purposes, to consider you for potential future roles, and to perform research. Thereafter, we retain a minimal amount of your Personal Information to record your recruiting activity with us.

We may need to retain your information for a longer period where we need your Personal Information to comply with applicable regulatory or reporting requirements, legal obligations, or where we may need it for our legitimate purposes, e.g., to help us responding to queries or complaints, fighting fraud, responding to requests from regulators, resolve disputes, enforce our agreements, etc.

We do not carry out any processing activities that involve automated profiling and/or automated decisions.

To exercise your rights or if you have any concerns as to how your data is processed, you may contact Globalization Partners Privacy Office, as follows:

Email: privacy@g-p.com (add “Personal Information Access” in the subject line).