Privacy notice for candidates

Checkout Ltd and its affiliated companies (“Checkout.com”, “we”, “our”, or “us”) are committed to protecting and respecting your privacy.      

As a data controller, we are responsible for deciding how we hold and use personal information about you. This privacy notice applies to candidates that apply for a role with Checkout.com. This notice sets out the basis on which any personal data that you provide to us, or that we otherwise collect, will be processed by us. The purpose of this notice is to provide candidates with information on the types of personal data Checkout.com will collect, use and retain and to provide guidance on the reasons for doing so. Some of the processing activities stated in this notice will not always apply to all candidates. Additional and specific information will be provided to candidates at the time data is collected to ensure they are informed of how Checkout.com will use the data and the legal basis for processing the data.

It is important that you read this notice, together with any other documentation we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

1.    OUR DATA PROTECTION PRINCIPLES

We will comply with data protection principles. These principles say that the personal information we hold about you must 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.

2.    DATA PROTECTION OFFICER  

Our Data Protection Officer (DPO) was appointed to oversee compliance with data protection law and this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO using [email protected].

In addition, you have the right to make a complaint at any time to the supervisory authority in your jurisdiction.

3.    WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect, store and process personal information about you for the following purposes:

  • To contact you in relation to your application to work with us.
  • To assess your skills, qualifications and suitability for a role at Checkout.com.
  • To determine your eligibility to work in the jurisdiction to which you have applied.
  • To review references in order to determine your suitability for the roles you apply for.
  • To determine whether any reasonable adjustments need to be made as part of the application process.
  • To conduct applicant surveys in order to assess the impact and effectiveness of Checkout’s external inclusion initiatives.
  • To carry out background checks to reduce the risk of misconduct.
  • To ensure the safety and security of our premises.
  • To respond to any disputes or legal proceedings affecting us.
  • To conduct research about your experience and education.
  • To progress with your applications for other vacancies and alert you about vacancies you may be interested in.
  • To keep records related to our hiring processes.
  • To comply with legal or regulatory requirements including, without limitation, the obligation to combat money laundering, terrorist financing, corruption and bribery or the obligation to comply with data subjects’ requests in accordance with their rights under any relevant data protection law, we may screen your personal details with background checks providers or enquire about your personal data with other relevant providers.
  • To enter into a contract with you if your application is successful.

4.    INFORMATION WE MAY COLLECT ABOUT YOU

We collect, store, use and process all or some of the following categories of personal information about you:

Personal details and contact information provided by you as part of a direct application via Checkout.com’s job board or by email: name, email address, phone number, current company, Linkedin URL, language, salary expectation (where applicable).

  • Personal information in your CV/covering letter, which may include any information that you provide to us in support of your application (e.g. employment history, education, professional experience, and other incidental information that may be provided such as information about your nationality, postal address or residential information).
  • Relevant information from publicly available online sources or referrals.
  • Reference information, including information provided by third parties.
  • nformation related to any test results and portfolios as part of the interview screening process.
  • CCTV images upon attendance for interview at our premises (or electronic images if the interview takes place using an online meeting platform).
  • Any demographic information obtained during the application or recruitment process, on a voluntary basis (e.g. gender, pronouns, age).
  • Credit history and other results of background checks to comply with our legal and regulatory requirements.

We may also collect, store, use and process the following “special categories” of more sensitive personal information:

  • Information about your health, including any health issues as may be necessary to make any reasonable adjustments during the recruitment process.
  • Any demographic information obtained during the application or recruitment process, on a purely voluntary basis (e.g. race or ethnicity, disability or sexual orientation data).

5.    HOW DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

We collect personal information about candidates through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, referrals, credit reference agencies or other background check agencies. We may also collect information from publicly available online sources such as LinkedIn.

  • We will only use your personal information when the law allows us to. Most commonly, we will rely on the following legal bases to process your personal information:
  • Where it is necessary to enter into a contract with successful candidates.
  • Where we need to comply with a legal obligation (e.g. the provision of reasonable adjustments) or for purposes connected with a legal claim.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and your fundamental rights do not override those interests (and those legitimate interests are given in section 3 above).
  • We may also seek your consent (or explicit consent, where appropriate) where it is required in specific circumstances (e.g. where there is a legal obligation to obtain consent in your jurisdiction in order to process some specified sensitive personal information).
  • Where it is needed in the substantial public interest.
  • We may also use your personal information in the following situations, which are likely to be rare:
  • Where we need to protect your vital interests (or someone else’s vital interests).

5.1   Situations in which we will use your personal information

We process your personal data for the purposes set out in section 3 of this notice, which sets out a non-exhaustive list of the situations in which we will process your personal information. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

5.2   If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to process your application successfully (where the information is necessary for us to consider your application, such as evidence of qualifications or work history) or enter into a contract with you, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Failure to provide any demographic information as part of the application or the recruitment process will have no impact on the outcome of your application (as hiring managers will not know whether or not you have provided this data).

5.3   Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you prior to processing and we will explain the legal basis which allows us to do so.

6.    HOW DO WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION?

6.1   Information about your health

If you choose to submit such data, we will use information about your health, or disability status, to make any reasonable adjustments during the recruitment process and to ensure your health and safety.  

6.2   Demographic information about you

We may ask candidates to provide information about their gender, pronouns, sexual orientation, race/ethnicity, disability and age in order to assess the impact and effectiveness of our external inclusion initiatives. The provision of this data is purely voluntary, and as set out above, failure to provide any demographic information as part of the application or the recruitment process will have no impact on the outcome of your application (as hiring managers will not know whether or not you have provided this data).  

6.3   Your Consent

In some circumstances, we may seek your consent, in writing where required, to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your recruitment with us that you agree to any request for consent from us.

7.    DATA SHARING

We may have to share your data with third parties, including third-party service providers and other entities in the Checkout.com group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.  

7.1   Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law or where we have another legitimate interest in doing so.

7.2   Which third-party service providers process my personal information?

“Third parties" include service providers (including contractors and designated agents) and other entities within our group that process personal information about you. Examples of these are human resources service providers, external entities that provide IT services, such as platform providers, hosting and maintenance service providers, recruitment agencies, as well as providers that perform background checks, facilitate the electronic signatures of contracts or that create internal communications to the business.

Please note that this list may change, as we may need to use additional third-party service providers or replace some of these providers in the future.

7.3   How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. Where possible, 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.

Data protection law in some jurisdictions restricts cross-border data transfers in some circumstances in order to ensure an adequate level of protection for the rights and freedoms of data subjects.

Checkout.com will take all reasonable legal, technical, and organisational measures to ensure that if personal data is transferred outside of the jurisdiction in which the relevant data protection law applies, it will be treated securely and with an adequate level of protection in compliance with data protection law.

Where such law applies, Checkout.com will only transfer personal data internationally to another jurisdiction if appropriate safeguards (such as a binding adequacy decision, or model clauses etc.) are in place.

If you require further information about these protective measures, you can request it from [email protected].

7.4   When might you share my personal information with third parties?

We will share your personal information with other entities in our group when necessary during the course of the application or recruitment process, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

We may share your personal information with other third parties, for the reasons set out above at 7.1.

7.5   Transfer limitation

We will ensure that, where data is required to be transferred to a third party, the minimum possible amount of personal data is sent in order to meet the purpose for the transfer.

8.    HOW SECURE ARE OUR SYSTEMS?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed, or altered or disclosed, in an unauthorised way. In addition, we limit access to your personal information to those employees 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.

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.

9.    RETAINING YOUR INFORMATION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Retention Policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with our Data Retention Policy.

In general, if you are successful in becoming employed by us, we will keep your personal data for the duration of your employment and for a period afterwards in accordance with our Privacy Notice for Employees and Data Retention Policy. If you are unsuccessful in gaining employment with us, we will likely keep your personal data for a reasonable period after our last contact, in order for us to reach out to you if other opportunities arise, unless you request the deletion of your personal data or inform us that you would prefer not to be contacted. Should you choose to provide us with demographic data, this will be kept for a maximum of one year in order that we can analyse on an annual basis the effectiveness of our external inclusion initiatives.

10. YOUR RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION  

10.1 Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your application with us.

10.2 Your rights in connection with personal information

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.
  • Request the transfer of your personal information to another party.

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 [email protected].

10.3 What we may need from you

We may need to request specific information from you to help us confirm your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

11. RIGHT TO WITHDRAW CONSENT  

In the limited circumstances where you may have provided your consent (or explicit consent) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another basis for doing so in law.

12. STATUS OF THIS PRIVACY NOTICE  

This notice does not form part of any contract of employment that you may enter into with us and does not create contractual rights or obligations. Nothing in this notice is intended to create an employment relationship between us and any non-employee.

We reserve the right to update this privacy notice at any time, and we will update our privacy notice at https://www.checkout.com/legal/candidates-privacy-policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact [email protected].