Job Applicant Data Privacy Notice
March , 2023
AcedrA Pharmaceutical Company LLC having its registered office at Platinum Centre, Riyadh, Saudi Arabia (“AcedrA”) is responsible for the processing of your personal information as it decides why and how it is processed, thereby acting as the “Data Controller”. It may exercise this responsibility alone or jointly with other company(-ies) affiliated with AcedrA, acting as “co-controller(s)”. In this Privacy Notice, “we” or “us” refers to AcedrA and its Subsidiaries and/or Affiliates.
For the purpose of the scope of this data privacy notice (“Notice”), job prospects or candidates mean individuals who apply to an open position with us, who are contacted for or express interest in employment with us, or who attend a recruitment event or undergo an interview or assessment with us. This includes prospective employees, interns, and contractors (who will be further referred to in this Notice as “you”).
We invite you to carefully read this Notice, which sets out in which context we are processing information that relates directly or indirectly to you as an individual (“personal information”) and explains your rights with respect to the processing of your personal information.
We consider privacy a very important matter. We are committed to ensuring that any personal information we receive is processed and protected in accordance with applicable data protection laws and AcedrA policies and standards.
The purpose of this Notice is to clarify the way we are processing personal information. In this context, we are committed to keeping you fully informed about our activities involving the processing of your personal information pertaining to talent management, scouting, assessment and acquisition activities, and application, in general, for positions with us.
We have separate privacy notices in relation to processing the personal information of our employees, business partners, patients, and users of our websites, and you should refer to those where appropriate.
Should you have any further questions in relation to the processing of your personal information, you are invited to write an email to us at email@example.com
1. What personal information do we process about you?
In the context of the above described, we will only process information that is relevant to you as a job prospect or a candidate, which in some cases might require key strategic validations for skills and professional standing.
We mainly collect personal information directly from you when you apply for a job in our application management system or when you participate in an interview or assessment. In such cases, we will act as a Data Controller of your personal information.
We can also obtain information from professional social networks, such as LinkedIn or other job boards, and from other publicly accessible sources (only information relevant to your professional life) for the purposes of actively approaching you with job opportunities. Should we not have already received your agreement to hold your data, on our initial contact with you, we will ask for your consent to hold your data.
We may also receive personal information when you apply through third parties like recruitment agencies or consultants. In such cases, the third party may also act as a Data Controller of your personal information. To exercise your data protection rights for the processing activities carried out by such third parties; you may need to contact the third party through which you have applied for a position with us. We may also receive your information (email address) when an employee has referred you for a position with us under the employee referral program. In such cases, you are notified that you have been referred by an employee, but your contact information is not retained after sending you a notification email. Through the notification email, you will be asked to apply in our application management system. We have documented employee referral guidelines in place.
Some information is generated automatically when you use or otherwise interact with our application management system to create an account and manage your job applications.
In connection with your application for an open position, we may process the following personal information:
contact and general identification information (e.g. name, preferred first name, last name, gender, ethnicity, disability, date and place of birth, nationality, email and/or postal address, fixed and/or mobile phone number, etc.);
social media profile information (i.e. when you use your social media accounts to register in our application management system; your profile details such as name, email address, and other information that you choose to make accessible to us when you connect your social media account with our talent management system)
family, hobbies, or interests (not mandatory and only as you deem necessary to share or voluntarily include in your CV/Resume);
past remuneration and benefits data (such as salary level and amount, bonus, stocks, options, insurance, lost incentives, and other benefits in the countries where required and to the extent legally permitted);
education, professional standing, and job preferences (such as employment and education history, professional qualifications, skills, college transcripts, letter of recommendation, certifications, and experience, past employers and their contact data, location preference, role preference (function and discipline), language preference, information necessary to complete a background check as required and legally permitted and other information you voluntarily provide in your CV/Resume/Cover letter)
electronic identification and systems access data (e.g. picture or facial image, publicly available profiles on social media, online identifiers/cookies, user name, passwords, secret questions and answers, system login and activity logs, access and connection times, sound or video recordings such as remote conferencing platforms, on-site CCTV or voice recordings for security purposes);
Only when legally permitted in your country, information pertaining to legal standing, credit, and background validations depending on the position’s responsibilities, information necessary to complete a background or credit or solvency check as well as judicial data and investigation data (e.g. proceedings, outcomes, information, documentation, and convictions). Please note that the performance of these checks will be dependent on several factors such as the position, as well as the local availability and viability of each AcedrA legal entity offering such a position. You will be provided with further details on this, should it be relevant to your application.
Insofar as strictly necessary and legally permitted, your sensitive personal information will be collected only if you voluntarily allow for disclosure (such as visible or reported disabilities or protected group belonging, religion, diversity, and inclusion-related information, or labor union membership).
More generally, We will process information that you voluntarily and willingly disclose mostly during interviews, and which should be strictly related to your professional capacity and fit for the corresponding open position.
You may also join AcedrA Network by registering yourself by providing some of your personal information as listed above and stay connected with us for news, career opportunities specific to your background, and exclusive messages from our associates about what it is really like to work for us. If you join AcedrA Network, your personal information is processed to periodically send you career-related communications and you can anytime opt out if you wish to do so using the link provided in our communication emails to you.
Our recruiters review job applications to determine the job fitment. Our recruitment processes are not based on automated decision-making.
You may, at any point in time and without any repercussions, manage, update or delete your personal information directly through your account or indirectly by requesting to us. We are committed to honoring your privacy at all times. Just notify your interviewer, HR, or Talent Acquisition representative about your concerns.
2. For which purposes do we use your personal information and why is this justified?
2.1 Legal basis for the processing
We will not process your personal information if we do not have a proper justification foreseen in the law for that purpose. Therefore, we will only process your personal information if:
we have obtained your prior consent;
the processing is necessary to perform our contractual obligations towards you and to take pre-contractual steps at your request; the processing is necessary to comply with our legal or regulatory obligations;
the processing is necessary to protect your vital interests or those of another person; or
the processing is necessary for our legitimate interests, which do not unduly
2.2 Purposes of the processing
We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process your personal data for the following purpose(s):
phone or electronic communications, including interviews in person or remotely;
conduct cognitive tests or personality assessments or other suitability evaluations, fitted to the corresponding open position;
perform background or employment checks (when applicable and legally permitted);
verify your identity, academics, or qualifications in relation to your application;
perform general analytics to improve our internal processes, as well as to provide a better service to you when applying for an open position with us;
administer your application using internal or external recruitment platforms like job boards,
as required under applicable law.
3. Who has access to your personal information and to whom your information is transferred?
In the course of our activities and for the same purposes as those listed in this Notice, your personal data can be accessed by, or transferred to the following categories of recipients or third parties, on a need-to-know basis to achieve such purposes:
our personnel (including personnel, departments, or other companies affiliated with or subsidiaries of AcedrA);
our services providers that provide services and products to us;
our IT systems providers, cloud service providers, database providers, and consultants;
any third party to whom we assign or novate any of our rights or obligations; and
our advisors and external lawyers in the context of the sale or transfer of any part of our business or its assets.
The above third parties are contractually obliged to protect the confidentiality and security of your personal data, in compliance with applicable law.
We may share personal data you submit as part of the application process with selected service providers or consultants acting on our behalf that may assist us in recruiting talent, performing data analysis, providing talent or application management systems, providing IT or related infrastructure, providing communication or reach out services, administering and evaluating pre-employment screening and testing, and improving our recruitment process. Your personal information can also be accessed by or transferred to any national and/or international regulatory, enforcement, public body, or court, where we are required to do so by applicable law or regulation or at their request.
The personal information we collect from you may also be processed, accessed, or stored in a country outside the country where we are located, which may not offer the same level of protection of personal information.
4. How do we protect your personal information?
We have implemented appropriate technical and organizational measures to provide an adequate level of security and confidentiality for your personal information.
The purpose of these measures is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access, and against other unlawful forms of processing.
5. How long do we store your personal information?
We will only retain your personal information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal or regulatory requirements.
The information you submit will be retained in the candidate database for a period of 12 months since you last updated your profile, or longer if you are still being considered for an open position, or if you have updated your candidate account (e.g. apply to another job, update your CV/Resume). Recruiters at AcedrA, AcedrA's subsidiaries, and affiliated companies will be able to access your Information and may contact you should a suitable opening arise.
If your information is shared with us by a recruitment agency, and you have consented accordingly, the Information will be retained for a period of 24 months since submission, or longer if you have updated your account or you are being considered for an open position.
Personal information collected and processed in the context of a dispute is deleted or archived (i) as soon as an amicable settlement has been reached, (ii) once a decision in last resort has been rendered, or (iii) when the claim becomes time-barred.
6. What are your rights and how can you exercise them?
Whenever we process Personal information, we take reasonable steps to keep your Personal information accurate and up-to-date for the purposes for which they were collected. We will provide you with the ability to exercise the following rights under the conditions and within the limits set forth in the law.
the right to be informed about what personal information we have about you and how we process your data
the right to access your personal information as processed by us and, if you believe that any information relating to you is incorrect, obsolete or incomplete, to request its correction or updating;
the right to request the erasure of your personal information or the restriction thereof to specific categories of processing;
the right to withdraw your consent at any time, without affecting the lawfulness of the processing before such withdrawal;
the right to object, in whole or in part, to the processing of your personal information. With certain exceptions, this includes the right to object to direct marketing and the right to object to your data being used for research.; and
the right to request its portability, i.e. that the personal information you have provided to us be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format without hindrance from us and subject to your confidentiality obligations.
the right to object to automated decision making including profiling, i.e. you can request human intervention in any automated decision-making process related to the processing of your data and where such processing is not based on your consent, authorized by law, or necessary for the performance of a contract. However, we don’t currently make decisions solely using automated processes
If you have a question or want to exercise the above rights, you may send an email to our data protection officer at firstname.lastname@example.org for application related to positions with us or send a letter to our local address with a scan of your identity card for identification purpose, it being understood that we shall only use such data to verify your identity and shall not retain the scan after completion of the verification. When sending us such a scan, you should make sure to redact your picture and national registry number or equivalent on the scan.
If you are not satisfied with how we process your personal information, your may address your request to our data protection officer at email@example.com who will investigate your concern.
In any case, you also have the right to file a complaint with the competent data protection authorities, in addition to your rights above.
7. How will you be informed of the changes to our Privacy Notice?
We may change or update this notice from time to time by posting a new privacy notice in our application management systems or our corporate website (https://www.acedrarx.com/privacy-cookies-policy). Please keep checking this notice occasionally so that you are aware of any changes.
I confirm that I understand the above-stated and I agree to the processing of my personal information. By submitting my application, I hereby authorize and consent to the basic background checks during the selection process, where legally permitted and as required for the specific open position, on my personal information as outlined above. Such checks may be performed or conducted by the corresponding AcedrA legal entity’s authorized third parties. I agree that my personal information will also be used to perform extended background checks, to the extent permitted by law and where required, later at the time of an employment offer by AcedrA when an extended background check notice will be provided to me.