EU/EEA, UK, SWITZERLAND JOB APPLICANT PRIVACY NOTICE
Effective Date: January 10, 2019
Ripple Europe Ltd (registered in England & Wales with company number: 10145333) and registered at 6th Floor, One London Wall, London, EC2Y 5EB, with offices located at 1 Angel Court, 16th Floor, London, EC2R 7HJ (the "Company", “we”, “our”, “us”) is committed to being transparent about the types of personal data we collect, how we may use that information, with whom we may share it, and the choices and rights you have regarding our use of your personal data. This Job Applicant Privacy Notice also describes the measures we take to secure your personal data, how long we retain it, and how you can contact us to exercise your rights.
This notice explains how Ripple Europe Ltd and its affiliates, collect, handle and use personal data we collect relating to job applicants ("Applicant Notice"). Where we refer to “we” or “our” or “us” we are referring to Ripple Europe Ltd and its affiliates, and where we refer to “you” or “your” we are referring to job applicants.
INFORMATION WE COLLECT
Information You Provide to Us
Ripple Europe Ltd collects certain information, including personal data, about you that you may provide to us for recruitment purposes, including:
- Contact information (such as your name, address, email address, and telephone number);
- Your qualifications, education skills, work experience and employment history;
- Your remuneration including benefit entitlements;
- Other content you provide (such as references, transcripts, photographs, videos, articles, and comments);
- Information about your entitlement or eligibility to work;
- Interview records and interview test results; and
- Information from public profiles.
We may collect this information in a variety of ways, including:
- Through application forms (online and electronic), CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment;
- Through CVs or resumes, obtained from recruiters who submit it to us on your behalf; and
- Through third parties, such as references supplied by former employers. We will seek information from third parties generally once a job offer to you has been made and will inform you that we are doing so.
Special Categories of Personal Data
We also collect special categories of personal data in particular health data, including whether or not you have a disability for which the organization needs to make reasonable adjustments during the recruitment process, and other special categories of personal data such as racial or ethnic origin.
Depending on the role that you apply for, and only if we offer you a contract of employment, we will also process criminal records and information regarding criminal offences or proceedings if revealed in a background check. For roles involving the processing of financial information, we are also obliged to seek information about your credit history.
Information We Collect by Automated Means
When you visit our ‘Careers at Ripple’ website, we obtain certain information by automated means, such as cookies, web beacons, web server logs and other web tracking technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Careers Site.
The information we collect through cookies and similar technologies helps us (1) remember your information so you will not have to re-enter it; (2) understand how you use and interact with our website; (3) measure the usability of our website and the effectiveness of our communications; and (4) otherwise manage and enhance our website and help ensure it is working properly. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. You can also opt-out of receiving cookies by adjusting your browser settings. Please note, however, that without cookies you may not be able to use all of the features of our website.
HOW WE USE YOUR INFORMATION
We process your Personal Data for the purpose of administrating your application process. More specifically, we use your Personal Data:
- To administer and manage your application process; carry out our human resources functions and activities and in order to take pre-contractual steps at your request;
- To evaluate your education and working skills, qualifications and your suitability in connection with your selected job opening and/or for available positions;
- To take measures to verify that the information you have provided is true and accurate, such as reference checks;
- To conduct (criminal and credit) background checks to the extent authorized by law and as required for your role;
- To keep your record for future hiring needs, including for the purpose of contacting you regarding possible employment;
- To deal with legal disputes and to establish, exercise and defend (potential) legal claims;
- For monitoring equal employment opportunities; and
- To comply with applicable (employment) laws and regulations, in particular health and safety and anti-discrimination legislation.
HOW WE STORE YOUR INFORMATION
Personal data will be stored in a range of different places, including on your application record, in our Human Resources management systems and on other IT systems (including email). If your application is unsuccessful, we may keep your personal data on file in case there are future employment opportunities for which you may be suited, if you have consented to such.
HOW WE SHARE YOUR INFORMATION
Your information may be shared for the purposes of the recruitment exercise. This includes members of the Company’s Human Resources department and the Recruiting team, interviewers involved in the recruitment process, managers in the business area with a vacancy, and IT staff if access to the data is necessary for the performance of their roles.
If your application for employment is successful, we will then contact your former employers to obtain references for you, and depending on the role that you have applied for, with employment background check providers to obtain necessary background checks.
We also may disclose personal data about you: (1) if we are required to do so by law or legal process; (2) for the purposes of, or in connection with, any legal proceedings, or otherwise for the purposes of establishing, exercising or defending any legal rights; (3) to law enforcement authorities or other government entities based on a lawful disclosure request; or (4) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
We reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with this privacy notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal data with any inquiries concerning the processing of that information.
TRANSFER PERSONAL DATA TO OTHER COUNTRIES
We transfer your personal data to countries outside the United Kingdom and the European Economic Area (“EEA”), including, but not limited to the United States, where our Human Resources Department and Recruiting team is located, and where our Human Resources management systems and on other IT systems (including email) are located.
Ripple is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, you can invoke binding arbitration for complaints regarding Ripple’s Privacy Shield compliance. For further information, please refer to: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
In cases of onward transfer to third parties of Personal Data received pursuant to the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, Ripple shall remain potentially liable.
HOW WE PROTECT YOUR INFORMATION
We are committed to protecting the security of your information. We maintain appropriate administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
HOW LONG WE RETAIN YOUR DATA
If your application for employment is successful, relevant personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper copies). At this stage, your personal data will be processed in accordance with our Employee Privacy Notice.
If your application is unsuccessful, we may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will use your personal data for this purpose in light of our legitimate interests in staffing vacancies. If you do not wish for us to keep your data, please contact us (see below for our contact information) to have your personal data deleted.
As a data subject from the EEA, you have a number of rights in regard to your personal data. You may have the:
- Right to Access: You have the right to request access to any of your personal data that we hold and to request a copy of your data.
- Right to Correction and Deletion: We will take steps to maintain correct personal data. We encourage you to keep us up to date in order to ensure that changes in personal circumstances (for example, change of address, etc.) are reflected in our database; You have the right to request correction of any inaccurate personal data relating to you or to request deletion of any irrelevant personal data we hold about you.
- Right to Restrict Personal Data Use: You have the right to restrict our use of your personal data where (i) you contest the accuracy of the personal data; (ii) the use is unlawful, but you do not want us to erase the personal data; or (iii) we no longer need the personal data for the relevant purposes, but you require it for the establishment, exercise or defense of legal claims.
- Right to Data Portability: To the extent that we use your personal data for the performance of the employment contract and that Personal Data is processed by automatic means, you have the right to receive all such personal data that you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.
- Right to Object: To the extent that we are relying on our legitimate interests to use your personal data, you have the right to object to such use, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms, such as where we need to process the personal data for the establishment, exercise or defense of legal claims.
- Right to Withdraw Consent: In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time by sending an email to email@example.com specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to Lodge a Complaint: In compliance with the Privacy Shield Principles, Ripple commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Ripple at firstname.lastname@example.org. Ripple commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship. You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe that the organization has not complied with this Privacy Notice or your data protection rights. For the UK, you can contact the Information Commissioner's Office at 01625 545740 or via email at https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
Please note that we may need to retain certain personal data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. For further information regarding your rights, or to exercise any of your rights, please contact us at email@example.com.
CCTV (CLOSED CIRCUIT TELEVISION) / SURVEILLANCE
We have installed CCTV systems in some of our premises used by members of the public, visitors to our office, and our employees. The principal purpose of the CCTV system is for the prevention and detection of crime, and to ensure the safety of employees, visitors and members of the public.
Images captured by CCTV will not be kept for longer than necessary. However, on occasions there may be a need to keep images for longer, for example where a crime is being investigated. We will only disclose images and audio to other authorized bodies who intend to use it for the purposes stated above. You have the right to see CCTV images of yourself and be provided with a copy of the images.
Recruiting processes are not based solely on automated decision-making.
To submit questions regarding this privacy notice, or to exercise your rights you can contact us by emailing us at firstname.lastname@example.org or at our U.K. mailing address at:
Ripple Europe Ltd
1 Angel Court, 16th Floor
London, EC2R 7HJ