This policy applies to our customers, suppliers, applicants, business contacts, consultants and other third parties. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of applicable privacy legislation, the data controller is JAE Europe, Limited of Royal Pavilion Tower 3, First Floor, Wellesley Road, Aldershot, Hampshire, United Kingdom GU11 1PZ. Our registered company number is 03244456.
Questions regarding this policy should be directed to our Data Protection Compliance Manager who can be contacted at firstname.lastname@example.org. The Data Protection Compliance Manager is responsible for ensuring compliance with relevant data protection legislation and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.
- Personal contact details such as your name, title, address, telephone number and e-mail address.
- Recruitment information (including personal information such as copies of your right to work documents, your CV or cover letter which is sent to us as part of the application process).
- Information provided to us by recruitment agencies in relation to your application for employment with us.
- Information collected during the course of your application including psychometric and personality test data (i.e. tests administered by our third party test supplier).
- Contact details such as your name, title, business telephone number and business e-mail address.
- Information that you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company.
- Other personal information you provide to us via our website, for example, by using the “contact us” forms.
- Information gathered when you visit our offices.
- Any personal information you provide to us during your interactions with us.
- Information provided to us by third party service providers we work with, for example, analytics providers.
2. How will we use your personal information and what is the legal ground we rely on for doing so?We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:
- Where you have provided us with your consent for us to do so;
- Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you;
- Where we need to comply with a legal obligation to which we are subject;
- Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
More specifically, we will use your personal information in the following circumstances:
- To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
- To carry out right to work checks – to comply with a legal obligation.
- Your contact details to provide you with information on our products and services. This may include technical information and/or marketing information – in pursuit of our legitimate interests in keeping you informed about our products, services and business updates.
- Dealing with your enquiry made via the “contact us” forms on our website – in pursuit of our legitimate interest to ensure your enquiry is dealt with promptly and efficiently.
- Your contact details to facilitate business between your company and ours – in pursuit of our legitimate interest of daily business with your company
- Health and safety purposes – to comply with a legal obligation.
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
- To transfer to third party service providers – in pursuit of our legitimate interests (in outsourcing for effectiveness and efficiency).
- To contact you if we wish to use your information for a purpose not set out in this policy – to comply with a legal obligation.
- Your contact details to provide you with information on our products and services. This may include marketing information – where you are a consumer and have provided us with your consent for us to do so.
3. What happens if there is a change of purpose?We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4.Which type of third parties might we share your personal information with?We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.
We may share your personal information with the following types of third parties:
- Technical support providers, for example, assisting with our website.
- Recruitment agencies assisting us with filling our vacancies.
- Professional advisers such as lawyers, accountants and business analysts.
- Providers which help us collate and organise information effectively and securely.
- Third party software hosting companies which provide us with software solutions.
- Providers which host our servers in their data centres in Germany, Japan and UK.
- Cloud storage providers in order to back-up our data.
- Our parent company and its subsidiaries.
5. Data retention How long will we use your personal information for?We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.
We assess the appropriate retention period for different information based on the size, volume, nature and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.
- Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.
- Where your application for employment is unsuccessful, we will keep your personal information, such as your CV and application details, for 6 months.
- The period we keep your personal information depends on a number of circumstances. For example:
* Where we have collected your personal information during the course of your and our organisations doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
6. Where we store your personal dataElectronic versions of your personal information are stored on our servers in the UK. We may also transfer personal data to our servers in Japan and Germany. We have put in place appropriate safeguards between our parent company and its subsidiaries to provide for the lawful transfer of personal data outside of the European Economic Area.
Where we use third party service providers to assist us, your personal information may also be stored in accordance with their practices and procedures. We require third parties to respect your personal information and to treat it in accordance with the law.
7. Rights of access, correction, erasure, restriction and portability: Your rights in connection with your personal informationUnder certain circumstances, by law you have the right to:
- Request access to your personal information (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 the erasure of your personal information. This enables you to ask us to delete or remove personal information when there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
- 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.
8. No fee usually requiredYou will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9. What we may need from youWe may need to request specific information from you to help us confirm your identity and ensure your right to access any personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.
Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails sent to you.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
11. What happens if you fail to provide personal information?If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our premises).
12. Right to complainYou have the right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (email@example.com).
13. Changes to this privacy noticeWe may change, modify, add or remove portions of this policy at any time, and any changes will become effective immediately.