APPLICANT PRIVACY NOTICE
1.1 SUMMARY OF HOW WE USE YOUR DATA
This privacy notice (the "Notice") sets out how the Adenza group uses your personal data when you apply for a position with us.
We will share your data within Adenza and to third party service providers which help support our application process, such as screening providers, pre-employment assessment providers, recruitment platforms, IT hosting and/or IT maintenance providers. If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), your data may be transferred outside the EEA or the UK but will be protected by adequate safeguards under the EU General Data Protection Regulation (GDPR) or the UK General Data Protection Regulation (UK GDPR), as applicable.
Adenza may process information revealing your personal data, including contact information, birth date, and Sensitive Personal Data such as race, ethnic origin, sexual orientation, and any disability in order to facilitate effective equal opportunities monitoring and/or to comply with legal obligations to make reasonable adjustments.
You have a number of rights in respect of the personal data that Adenza processes, including a right to object to certain processing. Please see the section below entitled “What rights do I have in relation to my personal data?”
1.2 WHAT DOES THIS NOTICE COVER?
This Notice informs you as to how Adenza and certain Adenza Group companies that may be involved in your application ("Adenza", "we" or "us") processes your personal data when you apply for a position with us.
It also describes your data protection rights, including a right to object to some of the processing which Adenza carries out. More information about your rights, and how to exercise them, is set out in the section below entitled "What rights do I have in relation to my personal data?"
Adenza may also provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.
1.3 WHAT INFORMATION DO WE COLLECT?
Adenza processes the following types of personal data when you apply for a position with us:
► Data you provide to us: Adenza collects and stores any data you provide us through your application, including your contact details; your application materials (CV, cover letter, previous work experience, education, and transcripts, and our notes from any interviews with you); your desired location; your desired salary; type of employment sought and date available; your identification documents (passport number, government identification numbers where permitted, immigration status); and any other data you submit to us, including any correspondence you may have with us during the application process.
► Data from other sources: Adenza obtains data about you from other sources, including recruiters, employment research firms, identity verification services, the references you provide to us, websites, and other publicly accessible data on the Internet. We will also receive data you submit to us through third-party websites. In certain countries, where permitted, we collect details of professional registrations, sanctions with professional bodies, financial checks, or criminal convictions where you have consented to background checks.
1.4 HOW DO WE USE THIS INFORMATION, AND WHAT IS THE LEGAL BASIS FOR ITS USE?
Adenza collects, uses, and stores your personal data for the reasons set out below:
► Where this is necessary for Adenza to review and assess your application for employment:
This includes assessing your skills and interest in career opportunities at Adenza, processing your application, analyzing your qualifications, verifying your identity and your eligibility for employment, and communicating with you about your application to respond to your inquiries and schedule interviews.
► Where necessary for Adenza's legitimate interests, as listed below, and where these interests are not overridden by your data protection rights:
Protecting Adenza's legal rights. This includes, but is not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.
Maintaining the security and integrity of Adenza's facilities, equipment, and electronic platforms. This includes administering access rights, monitoring compliance with company protocols, and where permitted by local law and in accordance with relevant policies, for investigations and disciplinary actions.
► Where necessary to comply with a legal obligation:
Disclosures to law enforcement agencies or in connection with legal claims, or regulatory purposes (including disclosure of such information in connection with legal process or litigation).
► Where necessary for the purposes of carrying out obligations in the field of employment and social security and social protection law under local law:
Information revealing race, ethnic origin, sexual orientation and any disability may be processed in order to facilitate effective equal opportunities monitoring and/or to comply with legal obligations to make reasonable adjustments.
► Where you have given explicit consent:
For example, Adenza shall ask for your permission to conduct a criminal background check, financial background check and personal reference check.
► If you fail to provide personal data:
If you fail to provide certain information when requested, we may not be able to perform all the activities related to your application process.
1.5 HOW DO WE JUSTIFY RELYING ON OUR LEGITIMATE INTERESTS?
Adenza evaluates and balances the interests of the parties for the data processing it carries out on the basis of its legitimate interests, which we have described above.
1.6 WHO WILL WE SHARE THIS DATA WITH?
Adenza will share your personal data with other members of the Adenza Group (as listed below) to review your application materials, and administer and manage group functions, including to make systems available to our employees or to refer you for other open positions.
Your personal data will also be shared with companies providing services under contract to Adenza, such as screening providers, pre-employment assessment providers, recruitment platforms, IT hosting and/or IT maintenance providers.
Personal data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the protection of Adenza's legitimate interests in compliance with applicable laws.
In the event that an Adenza business is sold or integrated with another business (in part or whole), your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business / business unit.
1.7 AUTOMATED DECISION MAKING
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
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.
1.8 DATA SECURITY
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
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.
1.9 WHERE WILL WE SEND YOUR DATA?
Your personal data will be processed in or accessed from jurisdictions outside the European Economic Area ("EEA") and the United Kingdom (“UK”) by us and by the third parties with whom we share your personal data.
When we transfer your data to organisations outside the EEA or the UK we use European Commission-approved standard contractual clauses to safeguard the transfer. Where we transfer personal data to a third party that has implemented Binding Corporate Rules, we may rely on those commitments to safeguard the transfer.
Your personal data may be transferred for the purposes set forth in this Notice to Adenza group affiliates and vendors in the EEA and non-EEA countries below, and a list of Adenza affiliates in those countries with their contact details, can be found in section 1.12 below.
1.10 WHAT RIGHTS AND CHOICES DO I HAVE IN RELATION TO MY PERSONAL DATA?
You have the right to ask Adenza for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine-readable format; and to ask us to share (port) this data to another data controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement or compelling interest).
Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Adenza processing your data, this will not affect any processing which has already taken place at that time.
These rights can be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. Relevant exemptions are included in the GDPR, the UK GDPR and other laws. Adenza will inform you of any relevant exemptions it relies upon when responding to any request you make.
Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage the recruitment process, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.
Adenza hopes that we can satisfy queries you may have about the way we process your data. If you have questions about this Notice, wish to contact us for any reason in relation to our personal data processing, or wish to exercise your data protection rights, please contact us at firstname.lastname@example.org or feel free to discuss this directly with your relevant recruitment contact.
If you have unresolved concerns, you may have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred.
1.11 HOW LONG WILL YOU HOLD MY DATA?
If your application is unsuccessful, we will retain your personal data only for 6 months or as long as we need it for Adenza's legitimate interests in accordance with applicable law.
If you accept employment with us, we will retain your personal data throughout your employment in accordance with a separate policy we provide to you.
1.12 WHO IS MY DATA CONTROLLER?
If You applied for a position with or are employed by a local affiliate of Adenza Inc, that affiliate is the controller entity and responsible for the processing of personal data described in this Notice. Please, consult the list below to check which entity is responsible for the processing of your personal data.
Adenza Australia Pty Ltd.
Suite 2004, Level 20, Australia Square Tower, 264 George Street, Sydney, NSW 2000, Australia
T +61 2 8270 7200
Adenza Brazil Ltda.
Rua Prof. Atílio Innocenti,
165, Vila Nova Conceição São Paulo,
SP 04538-000, Brazil
T +55 11 98611 5272
Adenza Canada Inc.
The Exchange Tower,
130 King Street West, Toronto,
T +1 416 800 0701
Adenza Chile SpA
Flor de Azucena 42, Oficina 61, Las Condes, Santiago, Chile
T +56(2) 2690 6800
Adenza China Co Ltd
12th Floor, Beijing Excel Center, No.6 Wudlinghou Street, Xicheng District, Beijing 100033, P.R. China
T +86 10 6612 6162
Adenza Colombia S.A.S
Av El poblado, Carrera 42 N° 3 sur- 81 Torre 1- Piso 7
Medellín, Antioquia 050021
T +57 604 5607683
Adenza France SARL
16/18 Rue du quatre Septembre, 75002 Paris, France
T +33 1 70 83 51 00
Adenza Germany GmbH
Neue Rothofstraße 13-19,
Adenza Hong Kong Ltd.
5407 Central Plaza,
18 Harbour Road, Wanchai
T +852 3918 3588
Adenza India Private Ltd
Unit 201, Akruti Center Point, MIDC Central Road, Marol MIDC, Andheri (E),
Mumbai 400 093
T +91 22 6106 5700
Adenza Ireland Ltd
1st Floor, Lumen Building, Upper Baggot Street,
T +353 1 539 8000
Adenza Israel Ltd.
2 Derech Agudat Sport HaPo ' el, Jerusalem 9695102, Israel
Adenza Japan KK
34th Floor, Marunouchi Building, 2-4-1 Marunouchi, Chiyoda-ku, Tokyo 100-6334, Japan
T +81 3 4577 4950
Adenza Technology, S. de R.L. de C.V.
Av. Paseo de la Reforma 404, Piso 6, Juárez, Cuauhtémoc,
06600 Ciudad de México, CDMX
Adenza Netherlands BV
Gustav Mahlerplein 109-115, 25th floor, 1082 MS Amsterdam, The Netherlands
T +31 20 369 0548
ADENZA Poland SOO
ul. Antoniego Słonimskiego 1/1A, 50-304 Wrocław, Województwo dolnośląskie, Poland
T +48 71 661 14 52
Adenza Singapore Pte Ltd.
18 Robinson Road, #14-01
T +65 6955 7600
Adenza Korea LLC
#1222, 146, Teheran-ro, Gangnam-gu, FastFive
T +822 6030 8831
Adenza Spain SL
Utopicus, C/ Gran Via, 4
28013 Madrid, Spain
United Arab Emirates
Adenza Technology (DIFC) Ltd.
Unit 1607, Floor 16, Index Tower, Dubai International Financial Center, UAE, 7477, UAE
T +971 4 514 9840
5th Floor, 80 Cannon Street,
London, EC4N 6HL
Tel: +44 20 3743 1000
99 Park Ave, Suite 930, New York, NY 10016, USA
T +1 212 905 0700
1.1 HOW TO CONTACT US
We have appointed a standing data privacy committee to oversee compliance with this privacy notice and evaluates all privacy related matters. This committee includes representatives of Legal, the People Office, Security, and IT. If you have any questions about this privacy notice or how we handle your personal data, please contact email@example.com.
If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at: firstname.lastname@example.org