Pax8 Job Applicant Privacy Notice
Last updated: February 2024
Learn more about our commitment to privacy protection
This privacy notice lets you know what happens to any personal information that you give to us, or any that we may collect from or about you. It also contains useful information about who to contact if you have a question or query.
Pax8, Inc. and/or its affiliated entities (“Pax8”, “we”, “us”, “our”, or the “Company”) are responsible for the processing of your Personal Information as described in this notice, in relation to the collection, retention, use and other processing of personal information that is obtained through the recruitment and hiring process, and act as the controller of such Personal Information.
As a controller of personal information, we are responsible for deciding how we process information about you. We take your privacy seriously and we are fully committed to protecting your personal information at all times. We will only process your personal information in accordance with the privacy legislation in the region you are located, this includes any replacement legislation coming into effect from time to time.
We may collect personal information (including special categories/sensitive data, and personal information relating to criminal convictions) that you submit to use in support of an application for a role with us.
When you apply for a job at Pax8, we may collect and process the following information about you:
• Your identification details, for example, your name, address, date of birth, gender, and contact details, including email address and telephone number.
• Details of your qualifications, skills, experience, education, and employment history, including your ability to fulfill job requirements.
• Information about your current compensation, including benefit entitlements to the extent permitted by applicable law.
• Evidence of your entitlement to work.
• Data you submit in résumés / CVs, letters, writing samples, or other written materials necessary for evaluation of employment.
• Data generated by interviewers and recruiters based on interactions with you.
• Social security numbers.
• Trade union membership, or membership of a professional or trade association.
• Immigration status and work permits.
• Information about your health, such as any disability you might have.
As appropriate and relevant to the job you are applying for, we may conduct background checks, including criminal background checks, to the extent permitted by applicable law. Background checks are performed in accordance with applicable law.
You are under no legal or contractual obligation to provide your personal information to Pax8 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.
We collect personal information about candidates from the following sources:
• You, the candidate.
• Existing Pax8 employees who refer or nominate you for roles with us.
• Recruitment agencies.
• Governmental authorities (such as local tax authorities).
• Your named referees who you’ve asked to provide us with references.
• Where permitted by law, third-party background screening providers, credit reference agencies, fraud prevention agencies, sanction screening and criminal convictions screening agencies; and
• Where permitted by law, other publicly available sources, such as social media networking sites (such as LinkedIn, Instagram, and Twitter).
We may process personal information to:
Purpose of processing | Legal Basis |
Assessing your skills, qualifications, and suitability for the role, including taking up references and conducting appropriate background checks. | Legitimate interests (to ensure we hire suitable candidates). |
Recruitment processes (including negotiation and communicating with you about your application). | Legitimate interests (to run a fair and efficient recruitment process). |
Complying with our legal and regulatory obligations, including for:
| Compliance with legal obligations. |
Recording interviews for quality control purposes and to train our interviewers. | Depending on local laws, either legitimate interests (to monitor the quality of our interviewers) or your consent. |
Carrying out equal opportunities monitoring. | Consent. |
Carrying out analytics in relation to Pax8’s recruitment practices. | Legitimate interests (to ensure we can improve our recruitment practices where necessary). |
Dealing with any legal disputes involving you or other prospective, current, or former employees, workers, or contractors. | Legitimate interests (to establish, exercise, or defend ourselves against legal claims). |
Quality assurance, monitoring, and staff training purposes. | Legitimate interests (to ensure our recruitment practices are carried out properly). |
Promote the safety and security of our personnel (including by detecting and stopping threats to our personnel and property). | Legitimate interests (to ensure the well-being and safety of our staff). |
Please note that the list of processing activities included in this section is not exhaustive. They are illustrative of the different types of processing that we may undertake. Please contact Pax8’s DPO if you have a question about whether we process your data for a specific purpose not listed in this section.
If you fail to provide personal information
If you fail to provide information when requested, that 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.
How we use special category or sensitive personal information
We process special categories of personal information or sensitive personal information for:
• Carrying out the obligations we have to exercise both Pax8’s and your specific rights which are imposed by employment laws;
• Establishing, bringing, or defending legal claims; and
• In the case of personal information about your physical or mental health, enable Pax8 to assess your working capacity and make decisions for occupational health purposes.
Automated decision-making
At this time, Pax8 does not make any decisions in the hiring process using automated means. If we make a material change to how we process your personal information, we will notify you and may also modify this Privacy Notice.
How we may share your personal information with third parties
We may share your personal information:
• Internally with our parent company, affiliates, subsidiaries, and other business units and departments within Pax8 for the recruitment and job selection process. This may include, for example, members of the human resources and recruitment team, interviewers involved in the recruitment 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.
• With third parties, including third parties located in the U.S., whom we engage to provide services such as hosting, supporting, and maintaining any recruiting platforms. These service providers are subject to strict contractual data processing obligations and do not use the data for their purposes but process it only on our behalf and in accordance with our instructions.
• Should we make you an offer of employment, we may contact former employers to obtain references for you (if we have a reasonable interest in verifying your information and this is necessary for verification purposes or if you have allowed us to contact your former employer) and with employment background check providers to obtain any necessary background checks, to the extent such background checks are permitted by applicable law and necessary to assess your suitability for the role/job for which you are applying.
• If we are involved in a reorganization, merger, acquisition, or sale of some or all of our assets, in which case we may disclose your personal information to the prospective seller or buyer (and/or its advisors). The recipient of the personal information will process the data as described in this notice and/or provide additional notice in accordance with applicable law.
• To abide by applicable law or protect our rights and interests. For example, we may disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or prevent fraud or abuse.
If we transfer your personal information we will put in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection laws and regulations. To ensure this level of protection for your personal information, Pax8 may use a data transfer agreement with the third-party recipient.
Please contact us if you want further information on the specific mechanism we have used to transfer your personal information.
Data security
We have put in place appropriate 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.
International transfers
Your personal information will be stored on servers located in the United States, UK, or EEA.
Where required by applicable laws, your consent to the transfer of your data outside your home country will be obtained as part of your application.
As an international organization, authorized personnel may access your data in any country in which we operate. Therefore, it may be necessary to transfer your details to members of our group located in countries that may not have equivalent data protection or privacy laws to those that apply in your own country. We may also need to transfer your data to third-party service providers located in other countries.
Regardless of where your personal information is transferred, we shall put in place appropriate safeguards to ensure that your data is treated securely and in accordance with applicable law. For individuals in the EEA and UK, this usually means entering into Standard Contractual Clauses with the recipients of your data who are located in countries that are not recognized as having adequate data protection laws. More details regarding these safeguards can be obtained from the DPO whose details are given below.
How long we retain your personal information
We will retain your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. Unless otherwise required or prohibited by law, we may retain the personal information of unsuccessful job applicants for up to four months after the recruitment decision. In some cases, you may consent to us maintaining your personal information for longer if you wish to be considered for future positions.
If your employment application is successful, personal information gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in the employee privacy notice.
You may have certain rights relating to your Personal Information, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
• Access your Personal Information held by us
• Know more about how we process your Personal Information
• Rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete
• Erase or delete your Personal Information
• Restrict our processing of your Personal Information
• Transfer your Personal Information to another controller, to the extent possible
• Object to any processing of your Personal Information
• Opt out of certain disclosures of your Personal Information to third parties
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”);
• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal; and
• Not be discriminated against for exercising your rights as described above.
If you want to review, verify, correct, or request the 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 contact [email protected]
Right to withdraw your consent
When you applied for this role, you 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 [email protected]. 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 information securely.
How to contact us
Pax8 has appointed a Data Protection Officer and an EU representative. To exercise your rights regarding your personal information or if you have any questions regarding this Privacy Notice or our privacy practices please fill out this form, email us at [email protected], call us at 1-855-884-PAX8 (7298), or write to us at:
Attn: Data Protection Officer
Pax8, Two the Distillery
2 Avon Street
Bristol BS2 0GR, UK
[email protected]
Attn: EU Representative
Pax8 Deutschland GmbH
Schumannstraße 27
60325 Frankfurt am Main
Germany
[email protected]
When you contact us, please indicate in which country and/or state you reside.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website.