Easybrain Applicant Privacy Notice

 

This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

 

Who collects the information

Easybrain (‘Company’) is the data controller responsible for processing your personal data. The entity with which you have signed your employment agreement is the specific data controller for your personal data. This entity may be part of the Easybrain Group, which includes affiliated entities and group companies (‘Group Companies’). In this notice, references to ‘we’ or ‘us’ mean the Company and its Group Companies, which may process your personal data for employment-related purposes.

Data protection principles

We will comply with the data protection principles when gathering and using personal information.

What information

We may collect the following information up to and including the shortlisting stage of the recruitment / hiring process:

For Prospective Employees:

Your name and contact details (ie address, home and mobile phone numbers, email address);
Information contained in your Curriculum Vitae and cover letter including information about your qualifications, experience, employment history, salary, portfolio, previous academic history, details of referees, interests and any additional information that we not explicitly require which however are provided in your Curriculum Vitae;

We may collect the following information after the shortlisting stage, and before making a final decision to recruit:

  • Information about your past academic and work history, and references from previous employers or educational institutions, as requested or provided.
  • Your nationality and immigration status and information from related documents, including but not limited to your passport or other identification and immigration information, your photo, your criminal records certificate, and health certificates;
  • If applicable, a copy of your driving licence.
  • Personal data contained in your passport or other identification document;

You are required (by law or in order to enter into your contract of employment) to provide certain of the categories of information contained above to us to enable us to verify your right to work and suitability for the position.

For Prospective Contractors/Freelancers:

  • Your name and contact details (ie address, home and mobile phone numbers, email address);
  • Information contained in your Curriculum Vitae and cover letter about your qualifications, experience, fees, portfolio, previous academic history, details of referees, interests and any additional information that we not explicitly require which however are provided in your Curriculum Vitae;

We may collect the following information after the shortlisting stage, and before making a final decision to hire for services:

  • A document evidencing your place of residence;
  • Information relating to individual entrepreneurs;
  • Information contained in your passport and/or identification card (including maintaining a copy);
  • Your social security card or certificate of state registration, if applicable;

You are required (by law or in order to enter into your contract of provision of services) to provide the categories of information contained above to us to enable us to verify your right to provide services and suitability.

How we collect the information

We may collect this information directly from you when you apply to relevant vacancies in our website, from a third party (sanctions screening providers), your referees (details of whom you will have provided), recruitment agencies that we may employ, talent acquisition agencies, social media websites (such as Linkedin) and websites through which you market your services.

Why we collect the information and how we use it

Managing Applications and Assessing Suitability:

We process your personal data to identify you as a potential candidate, review your application, and verify the information you provide or receive from other sources. This allows us to determine your eligibility and suitability for the position or other opportunities with us, including conducting assessments and pre-offer evaluations. The legal basis for this process is to take steps to enter into a contract with you and our legitimate interest in attracting and hiring qualified candidates, provided your rights and freedoms are not overridden.

Facilitating Recruitment and Pre-Hire Activities:

Your personal data is processed to facilitate recruitment and pre-hire activities, including reviewing your immigration status, supporting visa applications when necessary, and managing recruitment and interview processes. These activities are carried out to comply with our legal obligations, such as immigration requirements, and our legitimate interest in efficiently managing recruitment processes.

Communication Throughout the Recruitment Process:

We use your personal data to communicate with you about the status of your application and to inform you about other opportunities that may interest you. This processing is necessary to take steps prior to entering into a contract and is based on our legitimate interest in ensuring a transparent and efficient recruitment process.

Improving Recruitment Processes:

We process your data to analyze and enhance the efficiency and performance of our recruitment, hiring, and onboarding processes. This includes using insights to improve resource and financial planning. The legal basis for this processing is our legitimate interest in continuously improving recruitment practices to support business objectives.

Compliance with Legal Obligations:

Your personal data is processed to comply with applicable legal obligations, such as tax reporting, sanctions screenings, immigration reviews, and other regulatory requirements. These activities are necessary to fulfill our legal obligations and, where relevant, are carried out in the public interest.

Legal Claims:

We may process your personal data to establish, exercise, or defend legal claims related to your recruitment or employment. This processing is necessary to comply with legal obligations and to protect our legitimate interests in resolving disputes and ensuring compliance with applicable laws.

Employment Law and Public Interest:

In specific cases, we process your personal data to ensure equal opportunity, prevent or detect unlawful acts, or fulfill obligations under employment law. This processing is necessary for reasons of substantial public interest and to comply with legal obligations related to employment law.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

How we may share the information

We may also need to share some of the above categories of personal information with other parties, such as recruitment service providers and professional advisers. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information as required to comply with the law.

Where information may be held

Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents as described above. Information may be transferred internationally to other countries around the world, including countries that do not have data protection laws equivalent to those in the EU/EEA, for the reasons described above. We have security measures in place to seek to ensure that there is appropriate security for information we hold.

How long we keep your information

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed or engaged by us, the nature of the information concerned and the purposes for which it is processed.

We will keep recruitment information for no longer than is reasonable, taking into account the limitation periods for potential claims and our obligations pursuant to employment law. In certain cases, If there is a clear business reason and legitimate interests, we will retain your personal data for other current or future vacancies in order to give you the possibility to work with us in the future, even though we are currently unable to offer you a position, unless you object to this.

If your application is successful, we will keep only the recruitment / hiring for services information that is necessary in relation to your employment or provision of services;

Your right to object to us processing your information

Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Please contact our Data Protection Officer (DPO), who can be contacted via email at [email protected] if you wish to object in this way.

Your rights to correct and access your information and to ask for it to be erased

Please contact our Data Protection Officer (DPO) who can be contacted using the information explained above if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask our Data Protection Officer for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Our Data Protection Officer will provide you with further information about the right to be forgotten, if you ask for it.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your personal data. You can contact the DPO at [email protected].

[email protected]. If you believe that your personal data has not been handled appropriately or have unresolved concerns, you may contact the supervisory authority for our main establishment in Cyprus. The supervisory authority is the Office of the Commissioner for Personal Data Protection, which oversees compliance with data protection laws in Cyprus:

Alternatively, under the GDPR, you also have the right to lodge a complaint with the supervisory authority in the EU Member State where you habitually reside, work, or where the alleged infringement occurred.