Toluna Holdings Limited (incorporating Toluna, Harris Interactive in Europe and KuRun Data) (jointly referred to as the “Toluna Group of Companies” or “we/our/us”) is committed to protecting the privacy and security of your personal data, including applicants for any suitable roles we may have (“candidates” or “you/your”). You can find a list of all the entities within the Toluna Group of Companies at https://www.tolunacorporate.com/locations.

We are a “data controller” in respect of the processing of your personal data. This means that we are responsible for deciding how we hold and use personal data about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, but also for future potential roles and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

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

We will comply with data protection law. This says that the personal data we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

Personal data, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We will collect, store, and use the following categories of personal data about you:

• The information you have provided on our application form, including personal contact details such as name, title, addresses, telephone numbers, personal email addresses, date of birth, gender, employment history, skills, qualifications and experience.
• Information you have provided us in your curriculum vitae and covering letter/email;
• Any other information you provide to us during the course of your application, including during an interview.
• Passport and other information we may use to establish your identity.

  We may also collect, store and use the following types of more sensitive personal data:

• Information about your race or ethnicity.
• Information about your health, including any medical condition, disability, health and sickness records.

We collect these personal data about candidates from the following sources:

• You, the candidate.
• Any recruitment agency whom we engage in connection with your application.
• External platforms advertising our vacant job roles (such as Linked-in, Indeed, Monster, etc.)
• Your named referees, from whom we collect information about your prior employment history and/or education and/or exam results/qualifications.

6.1      We will only use your personal data when the law allows us to and to:

(a)      assess your skills, qualifications, and suitability for the role;
(b)      carry out background and reference checks, where applicable;
(c)      communicate with you about the recruitment process;
(d)      keep records related to our hiring processes;
(e)      comply with legal or regulatory requirements; and
(f)      with your consent to consider you for a further opportunity, which may arise in future

6.2      Having received your CV and covering letter and/or application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and identity checks before confirming your appointment.

6.3      Other Legal bases

We will use your personal data for the following legal bases:

1. where it is in our legitimate interests to do so:

• to decide whether to appoint you to the role, as it is beneficial to our business to appoint a suitable person to that role; and
• to decide whether to enter into a contract of employment or engagement with you.

6.4      If you fail to provide personal data

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

6.5      How we use your health information

We will use your health information to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.

6.6      Information about criminal convictions

We do not envisage that we will process information about criminal convictions.

6.7      Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

We will only share your personal data with the following third parties for the purposes of processing your application:

• Orange HR – our software provider of HR management and solution services;
• The recruitment agency who introduced you to us (if any); and
• Any member of the Toluna Group of Companies.

All such third parties are required to take appropriate security measures to protect your personal data in line with our policies. 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. We may transfer your personal data outside the EU and if we do, you can expect a similar degree of protection in respect of your personal data.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 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 personal data breach and will notify you and any applicable regulator or supervisory authority of a breach where we are legally required to do so.

How long will you use my information for?

We will retain your personal data for a period of six (6) months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal data for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, unless you are hired by us or if you opt in to agree to us continuing to process your personal data (as described below) we will securely destroy your personal data in accordance with our data retention policy.

We may wish to retain your personal data on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that. In such event, we will only retain your personal data if you have provided your explicit consent by opting in when you applied for the role via our website at https://www.tolunacorporate.com/about-toluna-group/about/careers-main. We will write to you periodically to confirm you remain on file and you may opt out of the processing at any time by notifying us at GDPR@Toluna.com.

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data 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 data. This enables you to ask us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data 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 data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact our DPO at DPO@toluna.com in the first instance. You also have the right to make a complaint at any time to your local data protection supervisory authority for data protection issues.

If you are in the EEA, we have registered with La Commission Nationale de l’informatique et des Libertés (CNIL) as our Lead Supervisory Authority. If you have an unresolved complaint that we have not addressed satisfactorily, then you may make a complaint to the CNIL.

If you are in the UK, you may make a complaint to the Information Commissioners Office at https://ico.org.uk/make-a-complaint/

We would, however, appreciate the chance to deal with your concerns before you approach the data protection regulator so please contact us in the first instance.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data. The date this privacy notice was published is set out on page 1.