Global Recruitment Privacy Notice for Applicants
This notice relates to the collection, use and disclosure of your personal data throughout the recruitment process by any member of the Lumos Foundation global family (including branches, affiliates, subsidiaries, Lumos Foundation USA Inc. and Fundación Lumos Colombia) (“Lumos”, “we” “our” or “us”) as data controller.
The personal data we process in relation to you is provided by you, third parties, collected through the Lumos website, or generated during your application for your employment with us, through any media.
Personal data that we may process, as appropriate throughout the recruitment process includes, but is not limited to:
- name and contact details (such as telephone number, e-mail address and postal address);
- date of birth;
- curriculum vitae/résumé;
- current and previous employment details;
- professional qualifications
- languages spoken and level of proficiency;
- evidence of identity such as national ID/passport/resident card;
- immigration status and work permits including work authorisations or other relevant documents;
- We may also process sensitive or special personal data where relevant to the recruitment process, including where necessary to accommodate any disability needs.
- Sensitive or special personal data processed may include but is not limited to:
- criminal record and, for a limited number of roles, security checks;
- health related information to enable any reasonable adjustments to be made.
We process your personal data for a variety of reasons in the recruitment process relying on the following bases for lawful processing:
- necessary to consider whether to enter into an employment relationship with you;
- necessary to comply with any legal right or obligations to which we are subject in relation to your employment or engagement such as the need to formally identify you, check your eligibility to work in a certain country, carry out enhanced criminal disclosure checks or, for a limited number of roles, security checks; or
- carried out with your consent, to carry out some criminal record checks, where countries laws permit;
- and includes but is not limited to the following:
- to process your application including to identify and contact you;
- to determine whether you have the professional skills, expertise and experience for the position applied for;
- if you are offered a position with Lumos, to verify the personal data provided including your identity, address, right to work, employment history, professional qualifications where relevant and where allowed by law, criminal record checks and security checks; and
- to provide you with information about other job vacancies if you wish to receive these.
We collect personal data in the following ways:
Website or by email
Depending on the country of application, we collect your Personal Data when you submit a job application and/or create a profile through our recruitment website or when you apply by email.
Your Personal Data may be provided to Lumos by recruitment agencies with whom you have registered an interest in working for Lumos. Where a recruitment agency refers you to us, a profile will be created for you in our recruitment database based on the information provided which will be deleted after six months if Lumos does not wish to progress with those registered.
Your Personal Data may also be collected from third parties during the recruitment process such as references from previous employers.
Lumos operates in a number of countries around the world and any authorised employee, agent and adviser in any of those countries may be involved in processing your recruitment application and have access to your personal data.
Your Personal Data may be disclosed to any of the following for any of the purposes outlined above but we will only disclose to them any personal data necessary for them to provide the services, where relevant:
- professional advisers, third party service providers, agents or independent contractors providing services to Lumos;
- any person in connection with litigation or other legal proceedings, to obtain legal advice or for establishing, exercising or defending legal rights;
- any person to whom disclosure is allowed or required by law and/or regulation;
- any court, tribunal, regulatory authority or governmental entity;
- any criminal records bureau or authority when conducting background criminal checks or security checks;
- to third parties to provide references at your request or with your consent; and
- third parties to whom we may transfer our rights and/or obligations under any agreement, including but not limited to a potential merger or acquisition.
Personal data is retained as long as necessary for the purpose for which it is collected and to meet legal, regulatory and operational requirements. If you are in a country where Lumos online recruitment system is available, your information will be kept longer if you wish Lumos to keep in touch with further job opportunities. Retention periods may differ for each country. At the end of the retention period, non-identifiable data is kept for management information purposes.
The security of your Personal Data is important to us and Lumos implements technical and organisational measures to safeguard your personal data including limiting access to those who have a business need to know.
Your personal data is stored in a variety of locations, including electronically on our secure servers and in hard copy form in access-restricted, locked filing cabinets.
As an international organisation, Lumos manages its people resources on a global basis and authorised personnel may access your Personal Data in any country in which Lumos operates. Your personal data may therefore be transferred to employees, agents, advisors or third party service suppliers, and other third parties authorised to act on our behalf in countries that may not offer equivalent data protection or privacy laws to that of the country where you are located. When using external service providers, we require that they adhere to security standards mandated by Lumos and regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that it is kept securely.
If you are applying for a position in the European Union (“EU”) and your personal data is processed in a country outside of the EU, we will put in place contractual clauses approved by the EU Commission as providing an adequate level of protection.
You should be aware that the Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorised third parties. We do not accept responsibility or liability for the confidentiality, security or integrity of your Personal Data in connection with its transmission over the Internet.
If you are offered a position with Lumos, criminal record and security search will be undertaken as required and where allowed by applicable law. You may also be required to consent to such checks being undertaken. If you do not give your consent where required, we will not be able to continue with the recruitment process including the withdrawal of an offer of employment. Lumos has a policy on the recruitment of ex-offenders which is available on request.
If you do not provide information where requested, provide misleading, false or inaccurate information or withhold any material information, we reserve the right to stop the recruitment process including withdrawing an offer of employment.
The recruitment privacy notice for applicants may be updated from time to time and it is your responsibility to visit our websites regularly for the most recent version.
If you wish to access, correct or request deletion of your Personal Data or have questions regarding this notice please email firstname.lastname@example.org
If you are registered to receive job alerts or other information and then subsequently you no longer wish to receive such information from us, you have the option at any time to contact us to ask for your profile to be deleted.
In some circumstances you may have the right to object to how we process your personal data or restrict its processing but this does not mean you can decide or choose how we process your personal data. If you have any concerns about how we process your personal data, please email email@example.com
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
If you have a complaint in relation to the processing of your personal data and you are not happy with the way we deal with it, please email firstname.lastname@example.org
The Data Protection Officer can be contacted at email@example.com or at The Lumos Foundation, Peninsula House, 30-36 Monument Street, London, EC3R 8NB
You also have the right to complain to the data protection authority, if one exists, in the country where you have a relationship with Lumos (in the UK the UK Information Commissioner who can be contacted at https://ico.org.uk/global/contact-us/.
For details please email firstname.lastname@example.org.
This Statement was last updated on 26 March 2019