Cubico is committed to protecting the privacy of anyone who applies for employment or other engagement with Cubico (“Candidates”).
Set out below is information regarding Cubico’s collection, analysis, disclosure and other use of Candidates’ personal information. If you accept employment with or are otherwise engaged by Cubico, Cubico will, of course, collect more information about you and make other uses of your information – this will be explained to you as part of the onboarding process.
The information Cubico collects about Candidates
Cubico collects information about Candidates in the course of the recruitment process. Some of this information is collected directly from you (for example, in forms that you are asked to complete, or in interviews or through the completion of tests). Other information is generated automatically when you use or otherwise interact with Cubico’s systems or provided to Cubico by third parties (for example, recruitment agencies, referees and educational institutions).
The information Cubico collects about Candidates includes:
- basic information about yourself, such as name, contact details and gender, and information provided to verify your identity;
- information regarding your employment and educational history, any role or roles for which you are applying or being considered and your relevant personal interests, attributes and career aspirations and plans;
- other information about yourself that you provide in a CV or similar document; and
- information regarding disability, which Cubico collects for equality of opportunity monitoring purposes, only with your explicit consent.
Generally you should assume that, if Cubico asks you for information, it needs it for its recruitment purposes. In some cases Cubico may not be able to consider your application if you cannot provide information that Cubico requests. There may be occasions where Cubico needs information to comply with a legal obligation, or conversely where provision of information is entirely optional and would not affect your application – Cubico will let you know if this is the case.
How Cubico uses Candidate information
Cubico uses Candidate information to manage the recruitment process and assess you for employment or other engagement, to monitor and improve Cubico’s recruitment processes and for related purposes, including equality of opportunity monitoring, compliance with law and regulation and purposes relating to legal claims made by or against Cubico.
Cubico is entitled to use, disclose and otherwise process Candidates’ (and former Candidates’) information as described in this notice because it needs to do so for the purposes set out above. Cubico does not rely on Candidates’ consent to collect, use or otherwise process their personal information other than in exceptional circumstances where its processing is genuinely optional (for example, collection of certain information for equality of opportunity monitoring as discussed in paragraph 2.2.4 above) – in those circumstances Cubico will ask for your consent on a case-by-case basis.
Disclosure of Candidate information
Cubico may disclose Candidate information, where reasonably necessary for the various purposes set out above, to:
- recruitment agencies working with Cubico in relation to your potential recruitment;
- other service providers processing Candidate information on Cubico’s behalf in the course of supporting its business and operations;
- other members of the Cubico group;
- third parties to whom Cubico is required to disclose information by law or regulatory requirement (including litigation counterparties); and
- competent regulatory and prosecuting authorities.
If you give Cubico names of potential referees, it may disclose the fact that you are applying to work with Cubico to them when it asks them for references.
International data transfers and related protections
The disclosures of Candidate information described above may involve international transfers, including transfers to countries outside the European Economic Area which do not have data protection laws as strict as those in the UK or other European Economic Area countries. In these cases, where Cubico transfers Candidate information to other members of the Cubico group or third party service providers acting on Cubico’s behalf, Cubico does so on the basis of agreements put in place to protect your information in a form approved for this purpose by the European Commission.
Retention and deletion of Candidate information
Cubico will generally retain information about you throughout the recruitment process. Some information will be retained after the process ends, either because you are employed or otherwise engaged by us or, if your application is withdrawn or unsuccessful, because Cubico retains information in case you apply to work for Cubico again or a recruitment-related dispute arises between Cubico and you. Cubico will usually delete this information (at the latest) one year after the recruitment process ends, although it may need to keep it for longer if you apply again or a dispute arises.
As a general principle, Cubico does not retain Candidate information (except in anonymised / statistical form) for longer than it needs it, given the purposes for which it is held.
Data protection rights and questions
With limited exceptions, Candidates have legal rights to be given copies of the personal information that Cubico holds about them and to require inaccurate information to be corrected. In some circumstances you can also require Cubico to delete (or stop making active use of) your personal information. If you wish to exercise any of these rights, would like to see copies of any of the agreements referred to above or have other questions about Cubico’s Candidate information processing or related policies, please contact Cubico’s HR Director at Floor 11, 70 St Mary Axe, London, EC3A 8BE, United Kingdom.
You also have the right, at any time, to lodge a complaint about Cubico’s processing of your personal information with the UK Information Commissioner (www.ico.org.uk) and/or, if you are applying for an opportunity in an EU member state, the relevant data protection supervisory authority in that member state – details of which are available at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.