Privacy Notice for Candidates

1. Purpose

OpenSymmetry is committed to protecting and respecting your privacy. OpenSymmetry is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker, or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (GDPR), the United Kingdom General Data Protection Regulation (UK GDPR), the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act (CPRA), and other federal, state, and international data privacy laws and regulations.


2. Data Protection Principles

We will comply with data protection law and principles, which means that your data will be:

    • Used lawfully, fairly and in a transparent way
    • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
    • Relevant to the purposes we have told you about and limited only to those purposes
    • Accurate and kept up to date
    • Kept only as long as necessary for the purposes we have told you about
    • Kept securely

OpenSymmetry has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. OpenSymmetry may also need to process data from job applicants to respond to and defend against legal claims.


3. The Kind of Information We Hold About You

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

    • The information you have provided to us in your curriculum vitae and cover letter including details of your qualifications, skills, experience, and employment history
    • The information you have provided on our application form, including your name, title, address, telephone number, personal email address, gender, employment history, qualifications, sponsorship requirements, and education history
    • Any information you provide to us during an interview, phone screen, or via email when you contact us throughout the recruitment process, such as information about your current level of remuneration, including benefit entitlements
    • Details of your visits to Workable’s Website including, but not limited to, traffic data, location data, weblogs and communication data, the site that referred you to the Workable’s Website and the resources that you access
    • Whether you have a disability for which OpenSymmetry needs to make reasonable adjustments during the recruitment process
    • Information about your entitlement to work in the country in which you are applying for a position and which may be collected as a result of reviewing your eligibility documentation
    • The results of the combined reasoning test assessment

We may also collect, store and use the following types of more sensitive personal information:

    • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
    • Information about your health, including any medical condition, health and sickness records
    • Information about criminal convictions and offences


4. Personal Information Collected

We collect personal information about candidates from the following sources:

    • You, the candidate
    • Workable, which provides us the ability to link the data you provide to us with other publicly available information about you that you have published on the Internet, such as LinkedIn and other social media profiles
    • Graduate Recruitment Bureau, a recruitment agency, from which we collect the following data:
      • Name
      • Title
      • Address, telephone number, personal email address, gender, employment history, qualifications, sponsorship requirements, and education history
    • Universal Background Screening and Checkr, background check providers, from which we collect the following categories of data:
      • Social Security Number, National Insurance number, or similar government issued ID number trace results
      • Sex offender search results
      • National and county criminal convictions and arrests
    • Third parties who may recommend you as a candidate for a specific job opening
    • Your named referees, from whom we collect the following categories of data: Dates of employment, previously held title, and salary information


5. How We Will Use Information About You

OpenSymmetry relies on legitimate interest as the basis on which we collect and use your personal information. OpenSymmetry’s legitimate interests are the recruitment of staff for our business.

We will use the personal information we collect about you to:

    • Assess your skills, qualifications, and suitability for employment with OpenSymmetry
    • Carry out background and reference checks, where applicable
    • Communicate with you about the recruitment process
    • Supplement information that we receive from you with information obtained from third parties
    • Keep records related to our hiring processes
    • Comply with legal or regulatory requirements
    • Help our service providers, such as Workable and partnered job sites, improve their services

It is in our legitimate interests to decide whether to appoint you to the role for which you applied since it would be beneficial to our business to appoint someone to that role.

We also need to process your personal information to decide whether to enter into a contract of employment or other agreement for services with you, including at-will employment in certain jurisdictions.

Having received your CV, cover letter, and your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role or contract work. At this stage in the recruitment process, we will ask you to take a combined reasoning assessment. We will use the results from the combined reasoning assessment test to decide to offer you the role. If we decide to offer you the role or contract work, we will then take up references and carry out a criminal record check before confirming your appointment.

If you fail to provide information when requested, which 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. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.


6. How We Use Particularly Sensitive Personal Information

We will use your particularly sensitive personal information in the following ways:

    • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
    • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.


7. Information About Criminal Convictions

We envisage that we will process information about criminal convictions.

We will collect information about your criminal convictions history if we would like to offer you employment. Employment is conditioned on criminal conviction checks and any other conditions, such as references, being satisfactory. We are entitled to carry out a criminal record check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.

In particular:

    • The role requires a high degree of trust and integrity since it involves dealing with customer data and/or internal data and so we would like to ask you to seek a basic disclosure of your criminal records history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.


8. Automated Decision-Making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.


9. Who Has Access & Data Sharing

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR 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.

If you are located in the UK, your data will be transferred outside of the UK in order for OpenSymmetry to carry out its recruitment activities. Data is transferred outside the UK on the basis of the UK Standard Contractual Clauses (UK SCCs).

We will only share your personal information with the following third parties for the purposes of processing your application:

    • Paylocity
    • Workable
    • Indeed and similar job posting sites
    • Graduate Recruitment Bureau
    • Universal Background Screening
    • Checkr

If you are applying for a position in a country where OpenSymmetry does not have a registered entity, we may also use a third-party employer to process your application, such as SafeGuard Global, CogNet (India), or Germer (Malaysia).

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.


10. 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. Details of these measures may be obtained from the DPO.

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.

However, the transmission of data via the Internet is not completely secure. OpenSymmetry cannot guarantee that your data will be secure when transmitted through any online means, and therefore, any transmission of your data remains at your own risk.


11. Data Retention

We will retain your personal information in Workable for a period of 24 months after we have communicated to you our decision about whether to appoint you to the role for which you applied or contract work. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.


12. Rights of Access, Correction, Erasure, and Restriction

Under certain circumstances, by law you have the right to:

    • Request access to your personal information (commonly 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 erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
    • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
    • 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.
    • Right to opt out of the sale of your personal information to third parties. This enables you to suspend the sale of your personal information to any third party and requires us to inform you of the third parties to whom we may sell your personal information.
    • Request the transfer of your personal information to another party.
    • Object to automated decisions being made which affect you or produce legal effects concerning you when such decisions are based solely on the automated processing of your personal information.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.


13. Right to Withdraw Consent

When you applied for this role, you provided consent to us to process 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 the DPO. 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 data securely.


14. Data Protection Officer

We have appointed an unregistered data protection manager to oversee compliance with this privacy notice, commonly referred to a Data Protection Officer or DPO. That post is held by Jon Gingell, Chief Information Officer, If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the California Attorney General’s office, or any agency or office having jurisdiction over data protection issues in which you reside.