Candidate Information Collection Notice
Mindsprint Pte. Ltd. and our affiliates worldwide (collectively, “Mindsprint,” “we,” “us,” “our”) understand the importance of privacy to you. This personal information collection notice sets out what personal information we may collect, in support of Mindsprint’ s recruitment process and, where applicle, your initial onboarding process as an employee, including through the use of our dedicated electronic portal (the “Purpose”).
Your personal data including your name, age, occupation, other biographical and professional information that may identify you (“Personal Data”) will be collected and stored by us and made accessible to Mindsprint staff and Mindsprint partners in order to evaluate your qualifications and suitability for employment with Mindsprint, and if employment is offered to you, in order to provide you with certain benefits and resources available to you as an employee.
We ask that you hereby acknowledge the collection, use and disclosure of your Personal Data for the specific Purposes below, in accordance with this Personal Information Collection Notice (“Privacy Notice”)
Personal Data Use:
Purposes and respective data categories:
- To assess your qualifications for employment with Mindsprint and communicate with you during the recruitment process: Your education, training, qualifications, previous work history, prior Mindsprint job application history, references, recommendations, verbal and written comments and submissions made or given during interviews and other interactions with Mindsprint will be used.
your contact information will be used to communicate with you during the recruitment process or in case we want to reach out to you in future for the same.
- To verify your qualifications, identity, and eligibility to work: Your biographical information including name, title, address, telephone number, personal email address, date of birth, gender, marital status, nationality, and languages spoken as well as education certificates, transcripts, and references, to verify your qualifications and identity.
Information displayed on LinkedIn and other social media, or public forums will also be used to verify your qualifications, identity and identify any supplemental information that may inform our decision-making process. We will also use Government identification cards such as Aadhar, PAN, etc. to confirm your identity and eligibility to work.
- Provide you with access to benefits and resources: Your name, photo, title, address, telephone number, personal email address, date of birth, gender, bank account details as well as government identifiers such as passports, identification cards, and other licenses to provide you access to certain benefits and resources such as talent management, processing of employment visas, payroll, health insurance, and tax filings.
(*If you are granted an offer letter and you accept)
- Improve the Mindsprint recruiting process and candidate outcomes: We will use your written and spoken feedback to assess and improve our recruiting and on-boarding processes. Where applicable, we will retain your candidate information for potential consideration of future roles, as per our Privacy Statement.
- Security: We will use your biographical information including name, photo, title, address, telephone number, personal email address, date of birth, and gender to give you access to our facilities and resources and to provide a safe working environment for our employees. We will also use your emergency contact information in case of emergencies.
In certain circumstances we may process personal data of third parties provided by you, such as references. Before you provide data relating to third parties to us, you should ensure you are permitted to do so and provide them with the information contained in this notice.
Lawful basis of processing: We will not process personal data without having a lawful reason to do so. Processing of your personal data will be done only if one or more conditions from the below mentioned list are valid.
- Consent (wherever recognized as a legal basis and provided by you)
- Mindsprint’ s legitimate interest in managing its workforce, operating its business, ensure appropriate training and supporting the welfare of its employees
by mitigating risks to health and safety and ensuring fitness for work
- To comply with the Regulatory obligations
- To enable us to perform any contract with you
Sensitive data Processing: We may also collect, store, and use information about your health, race or ethnicity, religious beliefs or sexual orientation known as "special categories" of more sensitive personal information to the extent this information is volunteered to us and subject to any local employment law or privacy requirements.
It is in our legitimate interests to decide whether to appoint you for work since it should be beneficial to our business to appoint someone for that work. We also need to process your personal information to decide whether to enter into a contract with you. If you become an employee, we will need to process your personal information to keep our employees safe and to provide you with benefits and resources for you to succeed in your role with us.
Consent Withdrawal: You may withdraw consent given, request for access and/or correction of Personal Data and/or request for information regarding our policies and practices at any time by contacting us at email@example.com. While no disclosure requested is obligatory, failure to supply Personal Data and/or subsequent withdrawal of your consent may affect our ability to provide certain services that you may have separately requested from us (as the case may be). In such instances where you revoke consent, we may retain such Personal Data to fulfil our legal/contractual obligations to you, if any, but will not use Personal Data for any other purpose unless compelled to do so by law.
In certain jurisdictions, consent may not always serve as the sole or primary legal basis for processing your Personal Data in certain circumstances, such as when processing the Personal Data of employees. However, in all jurisdictions Personal Data set forth and requested is processed for legitimate business needs and purposes and/or to enable us to comply with our contractual obligations to you (as applicable). If this applies to you, by clicking “Agree and Continue” below, you acknowledge you understand the bases on which we collect and process your Personal Data.
If you have any questions or concerns or do not consent to the collection or processing of any or all of your Personal Data for the Purposes stated, please do not enter the portal before speaking to your Mindsprint recruitment or HR contact at firstname.lastname@example.org.
How is your personal information collected?
We may collect personal information about you from the following sources:
- You sharing it with us through applications, online portals, emails, interviews, meetings or written submissions as part of the recruitment or initial employee on-boarding processes.
- The recruitment agency where you have applied or a Mindsprint contact.
- Background check provider including criminal background check, if applicable.
- Data from publicly accessible sources.
- We may also obtain some information from other third parties, for example, references from a previous employer, tax authorities, benefit providers, your named references, credit reference agencies.
If you fail to provide mandatory personal information: 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 nor on board you as an employee (as applicable). For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further. Similarly, if you do not provide information required to administer any employment contract or to comply with applicable law, we would not be able to facilitate the initial on-boarding process and thereafter.
Use of sensitive personal information: We may use your particularly sensitive personal information in the following ways:
- We will use information about your health/disability status to consider whether we need to provide appropriate accommodations during the recruitment process, or for the purposes of employment, for example whether adjustments need to be made during a test or interview or for the purposes of being able to carry out the relevant role.
- We will use information about your nationality, to ensure meaningful equal opportunity monitoring and reporting (where applicable and required).
- In every case, we will only use any sensitive personal information for the purposes for which we inform you. Where applicable data protection laws require us to do so on the basis of a specific lawful justification, such personal information is processed under one of the following bases:
- the processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or us in the field of employment law, social security and social protection law, to the extent permissible under applicable laws;
- the processing is necessary for reasons of substantial public interest;
- the processing is necessary to protect your vital interests or of another person where you are physically or legally incapable of giving consent (for example in exceptional situations such as a medical emergency);
- the processing is necessary for the establishment, exercise or defense of legal claims; or
- We obtain your consent to certain processing. You should be aware that without prejudice to the above paragraph concerning failure to provide mandatory information, it is not a condition or requirement of your application to agree to any request for consent from us.
Criminal conviction information: We do not envisage that we will process information about criminal convictions through this portal. If you are a shortlisted candidate or offered employment with us contingent on certain checks, we may, to the extent permitted or required by law, carry out a criminal record check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. This will apply in cases where:
- We may be legally required to carry out criminal record checks for those carrying out work in certain countries. The role is eligible for a check as per the local laws of the region where you have applied.
- The role requires a high degree of trust and integrity and so we would like to ask you to seek a basic disclosure of your criminal records history.
Where required by applicable law, we will seek your consent separately and/or comply with applicable local laws before processing any criminal record check data.
Automated decision-making: You will not be subject to decisions based solely on automated processing that will significantly affect you.
Data sharing: We will only share your personal information with the following Mindsprint affiliates and third parties for the purposes of processing your application:
- Respective Mindsprint teams depending upon the geographical area that you have applied or, if you become an employee, on the global businesses in which you perform your work;
- Other third-party service providers such as agencies that conduct online tests, support background verification, IT support, insurers, bankers, etc. who provide services necessary for the purposes mentioned in this privacy statement.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information 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 as mentioned in this notice and in accordance with our instructions. We may be required to disclose certain personal information to other third parties, including but not limited to regional governmental authorities (1) as a matter of law (e.g., to tax and social security authorities); (2) to protect our legal rights; (3) in an emergency where your health or security of is endangered; or, (4) for any other purpose required by applicable laws.
Overseas transfers: The information you provide here may be shared for recruitment purposes with one or more of Mindsprint companies. We may also share such information with our third-party service providers who process your information on our behalf. This means that the information you provide may be accessible by Mindsprint companies and other third parties outside of the country in which you are located. In some cases, the local laws regarding data protection will not necessarily be as strong as they are in the country in which you are located. However, we will ensure that if information is transferred outside your country of residence, it will still be treated in accordance with this Privacy Statement. If you are an EU data subject and your personal information is transferred outside the EEA to an Mindsprint affiliate or an entity in a country that is not subject to an adequacy decision by the EU Commission, your personal data will be protected by EU Commission approved cross-border safeguards including standard contractual clauses for cross-border data transfer.
We do not sell personal data to any third party or any other entity. In a case where your data is collected or processed in a jurisdiction that requires additional controls with respect to processing of personal information (apart from the controls mentioned in this statement), the respective Mindsprint entity will ensure compliance to the relevant requirements.
As explained above, we will share your personal information for certain specified purposes. Where your personal information is transferred outside the EEA to an Mindsprint affiliate or an entity in a country that is not subject to an adequacy decision by the EU Commission, your personal data will be protected by EU Commission approved cross-border safeguards including standard contractual clauses for cross-border data transfer.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors 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.
How long will we use your information for?
Mindsprint will retain your personal information for no longer than is necessary for the purposes for which the data was collected and in accordance with our internal retention policies and procedures. How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are also legal requirements that we keep some types of data for specific periods of time. We also retain your personal information 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. We may securely retain your candidate profile and recruitment information so we may contact you again if another suitable position arises. We will securely destroy your personal information in accordance with our internal retention policy.
Your rights in connection with personal information
Under certain circumstances, by law, and subject to our legal rights and obligations, 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 in a machine-readable format.
Right to withdraw consent given by you. This enables you to withdraw your consent for processing your information for the purposes of the recruitment exercise
Right to Complaint to a Supervisory Authority: You have the right to lodge a complaint with an applicable supervisory authority.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, restrict the use of information, request that we transfer a copy of your personal information to another party or withdraw your consent, you may write us at: email@example.com
The data controller for your information will be Mindsprint Pte. Ltd. and the relevant affiliated entity in your country, as applicable.