Candidate Privacy Information Statement
For candidates registering in the UK and internationally you will be registered on the Marlin App. As you’d expect, to properly perform our services, we collect and use information about you.
The Marlin App is committed to protecting and respecting your privacy. This Candidate Privacy Information Statement describes your privacy rights in relation to the information about you that we process, as well as the steps we take to protect your privacy.
What personal information does the company collect and use?
Personal information that the company usually collects includes, but is not limited to:
- Your name, date and place of birth, contact details and qualifications (education, training courses and internships), documents evidencing your identity and right to work and any other information you listed on your profile and work experience
- If you contact us, in some cases we will keep a record of that correspondence
- Feedback about you from our staff and third parties; where you give feedback on others, we usually keep that too and that is also personal information about you
- We may also collect information on your visits to our website/app including (but not limited to) your IP address, browser, timestamp, location, country traffic data, location data, weblogs and other communication data and the resources that you access. This information will make your visit to our website/app easier in the future. We might, for example, suggest new features based on your location
- We may also collect information for marketing purposes and analysis, including information on how you respond to email, SMS, phone and other marketing campaigns
- Details of any disabilities and any accommodations we may need to make for you in the workplace
- In some cases, we will also collect sensitive personal information where we are permitted to do so by law (so in some countries we will ask you about your background for equal opportunities monitoring).
Why do we use personal information about you?
- To provide you with the services you expect us to, like allowing employers to find your profile to discuss job opportunities. This includes access to your profile by prospective employers for their consideration and keeping you informed of future work opportunities by email, telephone, mail and/or other communication methods
- With your consent, we may also use your contact data for direct marketing for example via e-mail, messaging or telephone
- To further develop, test and improve our website/app, or other existing or new systems/processes to better serve you; this mainly takes place in the context of new IT systems and processes, so that information about you may be used in the testing of those new IT systems and processes where dummy data cannot fully replicate the operation of that new IT system
- To perform studies and statistical and analytical research, for example, to compare the effectiveness of our app between different sectors and geographies and seek to identify factors that might influence any differences we identify
- To transfer data to third parties (see below)
- Where necessary, to comply with any legal obligation
- We may also process your information to:
- a. promote the security and protection of people, premises, systems and assets
- b. monitor compliance with internal policies and procedures;
- c. administer communications and other systems used by the Marlin App (including internal contact databases)
- d. investigate or respond to incidents and complaints
- e. comply with obligations and rights and co-operate with investigations carried out by the police, government or regulators
Do you have to give us the personal information we ask for?
You are not obliged to provide your personal information to us, but it is more or less impossible for us to work with you and provide our services if you do not.
Do we process information about you without any human intervention at all?
Yes, we do at times. The Company may use automated systems/processes and automated decision-making (like profiling) to provide you, and employers, with the services you request from us. For example, when our clients are looking for candidates for jobs, they may conduct a search of our lists of candidates using automated criteria which takes into account your availability, skillset, pay rate and in some circumstances previous feedback we have received from employers to compile a shortlist which ranks which candidates are most likely to fulfil the employer's requirement. This means that sometimes your position in the rank may be higher than others, depending on how these factors match the employers’ needs.
How long do you keep my personal information for?
The Company will keep your personal information for as long as you wish to receive our services and for up to 2 years thereafter. If you are successful in finding work through the app, the Company will need to keep your personal information for a longer period in order to comply with its on-going legal and contractual obligations.
Do we transfer your data to third parties?
As mentioned above, we usually disclose your data to third parties. This is done to complete the purposes set out above. We do this in the following circumstances:
- To our suppliers. We may, for example, engage a supplier to carry out administrative and operational work in support of our relationship with you. The supplier(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions; the relevant suppliers are typically IT suppliers (who host or support our IT systems, including information about back-office finance and accounting management providers (who might need to handle details of candidates in order to process accounts payable and receivable).
- To our employers: We will share your data with employers in the app offering jobs/assignments you may be interested in, or who are interested in your profile. They owe contractual and other confidentiality obligations in relation to your data to us, and to you
- We will share your data with government, police, regulators or law enforcement agencies if, at our sole discretion, we consider that we are legally obliged or authorised to do so or it would be prudent to do so
- As part of due diligence relating to (or implementation of) a merger, acquisition or other business transaction we may need to disclose your data to the prospective seller or buyer and their advisers
Do we transfer your data outside the European Union?
Your data can be transferred and processed in one or more other countries, in- or outside the European Union.
We shall only transfer your data outside the EU to countries which the European Commission believes offers an adequate level of protection to you (a list of those countries is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm, or where the Marlin App has put in place appropriate safeguards to seek to preserve the privacy of your information (for which we usually use one of the forms of data transfer contracts approved by the European Commission, copies of which are available here: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
What are your rights?
As explained in the “Sharing with third parties” paragraph above, we share your personal information with the following:
- Right to access and obtain a copy of your personal information
- You are entitled to request confirmation whether we process any of your personal information. Where this is the case, you may have access to some of your personal information (via the app) and to certain information about how it is processed. In some cases, you can ask us to provide you with an electronic copy of your information
- Right to correct your personal information
- If you can demonstrate that personal information we hold about you is not correct, you can request that this information is updated or otherwise corrected. We would encourage you to access the app where possible and update your personal information directly
- Right to be forgotten/have data deleted
- In certain circumstances, you have the right to request that we restrict the processing of your personal data and/or that your personal data is deleted. You may make such a request at any time and our team will evaluate if your request should be granted, however, this right is subject to any legal rights or obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay. Please bear in mind, once your data is deleted – the Company might not be of service to you anymore once this data about you has been deleted. If you want to re-register with the Company again, you will need to re-enter your data
- Right to object
- As far as the company’s processing of your data is based on the company’s legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to the Company processing your data by reference to your particular situation.
If you want to exercise any of your rights, Email Us.
When you email us to exercise your rights, the Company may ask you to identify yourself before actioning your request.
Finally, you have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.
What about data security when using the Marlin App?
You are responsible for keeping your login details to the app safe, in particular, the password that we have given you or that you have chosen. These login credentials are for your own use. You are not permitted to share your credentials or other account details with any other person(s).
How could you contact us?
If you have any questions or concerns regarding our Statement, would like further information about how we protect your information (for example when we transfer it outside Europe) and/or when you want to contact the company’s Group Data Protection Officer (DPO) and your local Privacy Lead, please Email Us
How do we handle changes to this statement?
The terms of this Statement may change from time to time. We shall publish any material changes to this Statement through appropriate notices either on this website or by contacting you using other communication channels.