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PRIVACY
NOTICE

FOR (POTENTIAL) CANDIDATES
September 2023

Palmela is committed to protecting the individual privacy rights and choices of all our candidates and the personal information you share with us.

Our Privacy Notice contains important information about the types of personal information we collect and process; what we do with it; who we may share it with and why; and your rights when it comes to the personal information you provide us with. We may need to make changes to our Privacy Notice in line with regulatory requirements and will let you know if we do so.

1. WHO WE ARE

We have offices in London, Luxembourg and Lisbon. Please find the contact details for each office below.

2. TYPES OF DATA THAT WE PROCESS

We collect information about our prospective employees when they apply for employment with us and we process it on an on-going basis. We will process the following data:

  • Your application form containing your name, contact details, education and qualifications.

  • A copy of each reference obtained for you.

  • Documentary evidence of any qualifications.

  • In order to employ you, we are required to establish your identify and your right to work in the UK or the EU. We will need a copy of your birth certificate and passport (if any) (name, date of birth, nationality, photo, passport number).

  • If you require reasonable adjustments in order to attend for an interview, then we will process your health data.

  • Information about you from your referees. 

3. HOW WE USE YOUR PERSONAL DATA AND OUR LEGAL BASIS

We ask you for personal details to assess your suitability as a candidate and to provide the best possible recruitment experience.

 

ACTION

LEGAL BASIS

Your submission of your CV or application

Consent

We will then process the data in your application or CV and the data collected on you during the recruitment process in order to assess your suitability for the position.

Legitimate interest

Right to work checks

Legal obligation

We hold your CV and all data collected during the recruitment process for six months in the unlikely event of any employment tribunal claims; and

All personal data is stored securely on servers and in the cloud.

Legitimate interest

Information in order to make reasonable adjustments for you to attend an interview

Legal obligation

 

4. WITH WHOM WE SHARE YOUR INFORMATION 

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

 

ENTITY

LEGAL BASIS FOR SHARING

Our professional advisers such as lawyers and accountants

Legitimate interest

Government or regulatory authorities or law enforcement

Legal obligation

Professional indemnity or other relevant insurers

Legitimate interest

Regulators/tax authorities/corporate registries

Legal obligation

Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT support service providers, document and information storage providers.

Legitimate interest

Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide our services as effectively as we can.

We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal data appropriately and according to our legal and regulatory obligations.

 

5. WHERE YOUR INFORMATION IS PROCESSED

The majority of your information is processed in the United Kingdom, Portugal, Luxemburg and Switzerland. However, some of your information may be processed by us or the third parties we work with outside of the UK and EEA, such as the USA.

Where your information is being processed outside of the UK or EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK or European Union data privacy laws as applicable e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.

Our security controls are aligned to industry standards and good practice; providing a controlled environment that effectively manages risks to the confidentiality, integrity and availability of your information.

Please contact us if you would like to see our data sharing agreements and our international transfer safeguard agreements.

6. HOW WE PROTECT YOUR INFORMATION

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal data which is collected, recorded, or processed in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection responsibilities.

Your data is protected by controls designed to minimise loss or damage through accident, negligence, or deliberate actions. Our employees and consultants are trained to protect sensitive or confidential information when storing or transmitting data in any medium including electronically and must undertake annual refresher exercises on this.

7. HOW LONG WE KEEP YOUR INFORMATION FOR

We keep your data for as long six months if you are not successful. This is in case of any employment tribunal issues. If you are successful, then your recruitment data forms the start of your HR file.

8. HOW TO ACCESS YOUR INFORMATION AND OTHER RIGHTS

You have the following rights in relation to the personal data we hold about you.

Your right of access
If you ask us, we'll confirm whether we're processing your personal data and, if necessary, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we've shared your personal data with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.

Your right to erasure
You can ask us to delete or remove your personal data in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we've shared your personal data with others, we'll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.

Your right to restrict processing
You can ask us to 'block' or suppress the processing of your personal data in certain circumstances, such as where you contest the accuracy of that personal data or you object to us. If you are entitled to restriction and if we've shared your personal data with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.

Your right to data portability
You have the right, in certain circumstances, to obtain personal data you've provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are:

  • relying on our own or someone else's legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal data for direct marketing purposes.

Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the Supervisory Authority
If you have a concern about any aspect of our privacy practices, including the way we've handled your personal data, you can report it to the Supervisory Authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach the Supervisory Authority so please contact us in the first instance.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.