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Applicant Privacy Notice

Introduction

This Privacy Notice provides guidance and information to Independent News and Media PLC – herein referred to as “INM” (INM job candidates/applications – collectively the “Applicants”) regarding the processing of Applicant personal data by INM. For the purposes of this privacy notice “INM” shall mean Independent News & Media plus any Subsidiaries thereof and “Subsidiaries” has the meaning given to it by the Companies Act 1963 to 2003 as supplemented by the European Communities (Companies Group Accounts) regulations 1992.

INM (“us”, “we” or “our”) is committed to protecting and respecting your privacy. This Privacy Notice together sets out the basis on which any personal data we collect from you or that you provide to us in connection with your job application will be processed by us. Please read this Privacy Notice carefully to understand our treatment and use of personal data.

In this Privacy Notice, references to “you” means the person whose personal information we collect, use and process.

We will use your personal data only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of your personal data is in compliance with the Data Protection Acts 1988 and 2003 (as amended) and any subsequent data protection and privacy legislation, European Union Law including Regulation (EU) 2016/679, known as the General Data Protection Regulation or GDPR and any subsequent amendments (collectively referred to as “Data Protection Legislation”.

Please note that by submitting a job application with INM, you acknowledge that you have read, understood and agree to this Privacy Notice.

We seek to maintain the privacy, accuracy, and confidentiality of data (including your personal data) that we collect and use concerning our Applicants.

1. Identity Of The Controller Of Personal Information

1.1 For the purposes of Data Protection Legislation, the Data Controller is Independent News and Media PLC, a public limited company and registered in Ireland (Registered Number 2936) and having its registered office address at Independent House, 27-32 Talbot Street, Dublin 1.

1.2 INM and their affiliated companies will be referred to collectively as the “INM Group”.

2. Contact Details Of The Data Protection Officer

2.1 The data protection officer appointed in respect of your entity (if applicable) can be provided – please see “Contact Us” for further contact information.

3. When Does This Privacy Notice Apply

3.1 This Notice applies to personal information that we collect, use and otherwise process about you in connection with the job application process.

4. Processing Of Your Personal Data

4.1 How and why do we process your personal data?

INM will process your personal data for job recruiting and placement purposes, including notification of future job opportunities, human resources analysis and, for successful candidates, employment purposes. The personal data we process, the basis of processing and the purposes of processing are detailed below. Sometimes, these activities are carried out by third parties, including other members of INM Group (see “Sharing of Personal Data” section below).

We encourage you to supply only the information you are comfortable with. In particular, care should be taken when you supply special categories of data. Special categories of data could include: racial or ethnic origin, political opinions, religious or philosophical beliefs, religious, party or trade-union membership, as well as data concerning health, genetic code, addictions or sex life and data relating to convictions, decisions on penalty, fines and other decisions issued in court or administrative proceedings.

Personal data

  • identification data, including first name and surname, internal ID number;
  • contact information, including home address, phone/mobile/fax number, e-mail address;
  • gender, date of birth, citizenship;
  • data regarding responses to screening questions;
  • previous employment information, including date of hire, job title, department and business unit, work location, work status (full time, part time), data pertaining to work preferences and abilities;
  • resume, including education, past work experience and references; information on certain health conditions only when relevant for the fulfillment of the employment relationship with INM.

Basis of processing

  • It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you.
  • Consent

Purpose of processing

  • This is required to enable INM to administer the recruiting process, including the set-up of an electronic job applicant HR file, managing your application, organizing interviews, including notification of future job opportunities.
  • Retention of your personal data so that we may contact you in case of future job vacancies.

4.2 Where does INM obtain my personal data from?

Most of the personal data we process is obtained from you when you apply with INM but we also obtain personal data about you in the course of the application process (for example, during interviews or in general correspondence). Other data types may be obtained from third parties, including, for example, recruitment agencies.

In some circumstances, we may request your explicit consent to process (specific types of) personal data. In these circumstances, you are able to withdraw your consent at any time by following the instructions provided when you gave consent or at the contact details below]

5. Sharing Of Personal Data

5.1 Our Group Companies

Personal data will only be shared across INM Group in certain circumstances and where lawful to do so, i.e. it may be necessary to share successful candidate’s personal data with limited members of the human resources department, the finance department, and the IT department. Senior executive company managers may access and otherwise process your personal data in connection with their job responsibilities. INM takes appropriate steps to ensure that such personnel is bound to duties of confidentiality with respect to your personal data.

Your personal data will in particular be shared with:

  • Hiring Managers and HR for the purposes of the recruitment process.

5.2 Service Providers

We use third party service providers who provide technical and support services in connection with the application and recruitment process. In providing the services, your personal data will, where applicable, be processed by the service provider on our behalf.

We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal data. We will have written contracts with them which provide assurances regarding the protections that they will give to your personal data and their compliance with our data security standards and international transfer restrictions.

6. Transfers Outside The European Economic Area

6.1 Your personal information may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”), for example, when one of our service providers use employees or equipment based outside the EEA. For transfers of your personal data to third parties outside of the EEA, we take additional steps in line with Data Protection Legislation. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, e.g. we establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU commission’s model clauses.

6.2 If you would like to see a copy of any relevant provisions, please contact your data protection officer (see “Contact Us” section below).

7. How Is My Personal Data Secured

7.1 INM operate and use appropriate technical and physical security measures to protect your personal data.

7.2 We have in particular taken appropriate security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access, in connection with your employment. Access is only granted on a need-to-know basis to those people whose roles require them to process your personal data. In addition, our service providers are also selected carefully and required to use appropriate protective measures.

8. Storage Of Personal Data

8.1 If your application for employment is successful and you commence employment with INM, your personal data will be transferred to the individual’s employment / personnel file and will be processed for employment purposes in accordance with our internal rules for processing employee personal data.

8.2 We will keep your personal data for as long as it is necessary to fulfil the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. This may mean that some information is held for longer than other information. If you would like further information about our data retention practices you can ask for this at any time (see “Contact Us” section below).

9. Your Rights

9.1 You may have various rights under data protection legislation in your country (where applicable). These may include (as relevant):

Your right: Right of access

What does it mean? Subject to certain conditions, you are entitled to have access to your personal data which we hold (this is more commonly known as submitting a “data subject access request”).

How do I execute this right? Requests for such information should be made in writing to Data Protection Office. If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.

Conditions to exercise? We must be able to verify your identity. Your request may not affect the rights and freedoms of others, e.g. privacy and confidentiality rights of other Employees. Data solely retained for data backup purposes is principally excluded.

Your right: Right of data portability

What does it mean? Subject to certain conditions, you are entitled to receive the data which you have provided to us and which is processed by us by automated means, in a commonlyused machine readable format.

How do I execute this right? Requests should be made in writing to Data Protection Office. If possible, you should specify the type of information you would like to receive to ensure that our disclosure is meeting your expectations.

Conditions to exercise? The GDPR does not establish a general right to data portability. This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (e.g. not for paper records). It affects only personal data that was “provided” by you. Hence, it does, as a rule, not apply to personal data that was created by INM.

Your right: Rights in relation to inaccurate personal or incomplete data

What does it mean? You may challenge the accuracy or completeness of personal data which we process about you. If it is found that personal data is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate.

How do I execute this right? We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details, telephone number, immigration status. Please always check first whether self-help tools are available. If no such tools are available, requests should be made in writing to Data Protection Office.

Conditions to exercise? This right only applies to your own personal data. When exercising this right, please be as specific as possible.

Your right: Right to object to or restrict our data processing

What does it mean? Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.

How do I execute this right? Requests should be made in writing to Data Protection Office.

Conditions to exercise? This right applies only if the processing of your personal data is explicitly based on our so-called “legitimate interests” (see “basis of processing” above). Objections must be based on grounds relating to your particular situation. They must not be generic so that we can demonstrate that there are still lawful grounds for us to process your personal data.

Your right: Right to have personal data erased

What does it mean? Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”), e.g. where you think that the information we are processing is inaccurate, or the processing is unlawful.

How do I execute this right? Requests should be made in writing to Data Protection Office.

Conditions to exercise? There are various lawful reasons why we may not be in a position to erase your personal data. This may apply (i) where we have to comply with a legal obligation, (ii) in case of exercising or defending legal claims, or (iii) where retention periods apply by law or our statutes.

Your right: Right to withdrawal

What does it mean? You have the right to withdraw your consent to any processing for which you have previously given that consent.

How do I execute this right? Requests should be made in writing to Data Protection Office.

Conditions to exercise? If you withdraw your consent, this will only take effect for the future.

10. Your Right To Lodge A Complaint With A Supervisory Authority

10.1 Without prejudice to any other administrative or judicial remedy you might have, you may have the right under data protection legislation in your country (where applicable) to lodge a complaint with the relevant data protection supervisory authority in your country (i.e. the Office of the Data Protection Commissioner in Ireland) if you consider that we have infringed applicable data protection legislation when processing your personal data. This means the country where you are habitually resident, where you work or where the alleged infringement took place.

11. Changes To This Information

11.1 We may decide to make changes to this Privacy Notice. If the change is indicative of a fundamental change to the nature of the processing (e.g. enlargement of the categories of recipients or introduction of transfers to a third country) or a change which may not be fundamental in terms of the processing operation but which may be relevant to and impact upon you, then the updated Privacy Notice will be provided to you well in advance of the change actually taking effect. We will post the changes on our job website or send them to you via e-mail so that you will be aware of the changes. When notifying you of such changes, we will also explain what the likely impact of those changes will be to you, if any. In order to ensure fairness of the processing, we encourage you to review the content of this Privacy Notice regularly.

12. Contact Us

12.1 For further information or if you have any questions or queries about this Privacy Notice, please contact.

Data Protection Office
Independent News and Media PLC
Independent House
27-32 Talbot Street
Dublin 1

Email: data.protection@inmplc.com