Recruitment Privacy Policy

Last updated: September 2023

OTA Insight Ltd. and all other companies of the OTA Insight group of companies (“OTA Insight”) are committed to respecting your privacy and complying with the applicable data protection privacy laws and regulations.

This Recruitment Privacy Policy (“Policy”) informs you about how OTA Insight processes your personal information (“Personal Data”) during our recruitment activities. It sets out what kind of Personal Data OTA Insight may collect about you and from other sources, how OTA Insight processes your Personal Data during its recruitment activities, and what rights you have in relation to such data. “Personal Data” means information relating to you.

1. What personal data is collected?

OTA Insight collects Personal Data directly from you as well as from other available sources to the extent relevant and permitted by applicable local law. OTA Insight endeavours only to collect Personal Data that are necessary for the purpose(s) for which they are collected and to retain such data for no longer than necessary for such purpose(s). Subject to applicable local law and practice, the categories of Personal Data that are typically collected and processed in the recruitment context are:

Personal Data you provide

This information may include:

▪ your first name and last name, address, email address, phone number(s), education history, work experience, CV, resume, information about your primary country of residence and citizenship, additional countries, areas and communities of interest;

▪ whether you have ever worked for OTA Insight before, if you signed any or accepted any agreement or are otherwise subject to any restriction with your current or former employers;

▪ your disability, ethnicity, gender, race and religion.

▪ whether you require any accommodations/adjustments.

▪ Any other Personal Data you provide us with voluntarily.

Personal Data we collect

This information may include:

▪ Any cover letter or personal statement you provide;

▪ Any references you provide, or OTA Insight takes up to validate the information you’ve provided;

▪ Any interviewer or recruiter notes from interactions with you or with an employee that recommended you;

▪ If during the recruitment process you complete an assessment (written or in video), we may store the recordings of the assessment solely for the purposes of the recruitment process until closure of a position;

Personal Data processed if you receive and accept an offer of employment

This includes, but is not limited to, email address, first name, middle name, last name and employee ID.

2. How is your personal data being used?

OTA Insight will collect, use, store and otherwise process your Personal Data for the purposes of our recruitment or resourcing activities. Additionally, your Personal Data may be processed for other purposes you have consented to, or in cases where another legal basis applies or where we are legally allowed to do so. Whenever necessary and subject to statutory record-keeping requirements, OTA Insight will delete and/or anonymize Personal Data that are no longer needed. If there has not been any recent activity on your profile, we may delete your profile after a reasonable time in compliance with applicable laws. Otherwise we will maintain your profile as long as you retain it actively in our systems for you to be able to apply for available positions which may become available to you from time-to-time.

OTA Insight will generally process your Personal Data for the following purposes:

Verify your information and conduct relevant and appropriate legally permitted pre-employment and eligibility verification checks, as well as to assess your skills, qualifications and experience;
Comply with local, national or international laws, obligations and legal requirements;
Communicate with you about OTA Insight’s events, careers opportunities and the recruitment process including any interviews;
Contact you for other, future roles which may be of interest to you and aligned to your skillset.
Complete the selection process;
Conduct surveys and research activities with the objective of improving our recruiting process;
Perform analysis of our applicant pool to better understand who is applying to our positions and how to attract top talent;
Where legally permissible, we may ask you to voluntarily disclose your disability, ethnicity, gender and nationality, to help us Diversity and Inclusion programs (such as to assess the workforce, promote benefits and inclusive policies for the related population). However, we recommend that you do not actively disclose sensitive Personal Data (e.g., height, weight, religion, philosophical or political beliefs, financial data, sexual orientation, membership of a trade union or political party) in your resume/CV or any materials in support of your application;
Enable you to access our onboarding and other applications which help you to become familiar with the company, understand where and how you fit into the organisational structure and assist with your integration into the culture of the workplace.

By submitting your resume/CV or other information and any subsequent application materials to us, you agree that we may store and use such information for recruitment, hiring and employment purposes. You also agree that we may transfer the data outside of the EEA.

OTA Insight processes your Personal Data pursuant to several legal bases, depending on the type of data and purpose of the processing. Under most circumstances, our processing of your Personal Data in the recruitment context is based on your request in the anticipation of entering into an employment agreement with us. OTA Insight will also process this information where required to comply with legal obligations to which it is subject, such as mandatory reporting obligations. In some circumstances, OTA Insight will process your Personal Data pursuant to its own legitimate interests in operating its business, including conducting the above described activities for internal administrative purposes and ensuring network and information security. A different legal basis may be provided at the point where Personal Data is collected.

3. Who has access to your data?

It is OTA Insight’s responsibility to implement appropriate access control measures to ensure that your Personal Data is only accessed by persons having a clear need to know such information.

The extent to which your Personal Data are made accessible will depend upon the nature of the data concerned. Prior to hire, your Personal Data is not made widely available. Some Personal Data, such as your resume, job history, and other information relevant to assessing your fitness for the position to which you have applied, are made available as needed to the OTA Insight team you are seeking to join, others within OTA Insight with a stake in the applied for role, and appropriate members of the OTA Insight People Team. Except as needed to assess your qualifications for the role, access to most of your Personal Data is restricted to certain experts (e.g. Human Resources, IT or Legal) to the extent necessary to perform their work tasks.

4. Sensitive information

We aim to limit the collection of Sensitive Informationand shall only collect Sensitive Information if there is a legal justification for processing it, or if it is collected and processed with your express consent.

OTA Insight recognizes the additional need to protect Sensitive Information. All Sensitive Information is processed in strict compliance with applicable local law and only by a restricted number of individuals who have a clear and justified need to know such information.

Sensitive Information may be processed where necessary to enable OTA Insight to exercise its legal rights or perform its legal obligations in the field of employment law or related fields of law.

5. Transfer of your Personal Data

OTA Insight will not sell or otherwise disclose your Personal Data except as provided in this section:

Consent: OTA Insight may share your Personal Data if you have given your consent for OTA Insight to do so.
OTA Insight group companies and authorized third parties: OTA Insight may share your Personal Data with other OTA Insight group companies or authorized third parties who process Personal Data for OTA Insight for the purposes described in this Policy or otherwise provide recruitment related services to OTA Insight. In such cases OTA Insight will ensure that there is a genuine need to transfer your Personal Data and that measures are in place to safeguard the processing of your Personal Data through other OTA Insight companies or authorized third parties.
- Authorized third parties include, for example, recruitment agencies, professional advisors, external legal counsel, consumer credit reporting agencies, recruiting systems providers, providers of assessments and other third party suppliers.
- Authorized third parties may technically have access to your Personal Data in the course of providing their services but will be contractually restricted (or subject to a professional or statutory duty of confidentiality) from processing your Personal Data for other purposes. OTA Insight also requires them to act consistently with this Policy and to use appropriate security measures to protect your Personal Data.
International transfers of Personal Data: OTA Insight is a global company that has affiliates, business processes, management structures and technical systems that cross national borders. This means that your Personal Data may be transferred across international borders to countries other than the one where you are applying to as an applicant. Such other countries do not always have equivalent laws providing specific protection for or rights in relation to Personal Data or they have different rules on privacy and data protection. OTA Insight takes steps to ensure that there is a legal basis for such a transfer and that adequate protection for your Personal Data is provided as required by applicable law. Such steps include, for example, the use of standard contractual clauses approved by the European Commission or relevant authorities and the requirement to use appropriate technical and organizational security measures to protect your Personal Data. You may contact the OTA Insight Privacy Office at privacy@otainsight.com to obtain additional information about the safeguards taken by OTA Insight in connection with these transfers. A copy of the unchangeable Standard Contractual Clauses can be accessed on the webpage of the European Commission.
Mandatory disclosures: OTA Insight may be required by or under mandatory law to disclose your Personal Data to certain authorities or other third parties, for example, to government agencies responsible for the employment activities, statistical information or to the police or other law enforcement agencies, for example in context of conducting a background check.
Mergers and acquisitions: Where OTA Insight takes steps to sell, buy, merge or otherwise reorganize its businesses in certain countries, this may involve disclosing Personal Data to prospective or actual purchasers and their advisers. In such circumstances, OTA Insight will take all reasonable steps to ensure that appropriate measures to protect Personal Data are taken by such prospective or actual purchasers and their advisors.
Other: OTA Insight may disclose your personal data if it is necessary to protect your vital interests. OTA Insight may also disclose and otherwise process your Personal Data in accordance with applicable law to defend OTA Insight’s legitimate interests, for example, in legal proceedings.

6. Retainment of your Personal Data

If you accept an offer of employment, the Personal Data collected during your pre-employment period may become part of your employment record on OTA Insight’s personnel records, to be retained throughout and for a period of time after your employment with OTA Insight (specific periods vary by country).

If OTA Insight does not employ you, your Personal Data will only be retained for legitimate interests, and in any case in accordance with OTA Insight’s retention policy after which your Personal Data will be erased from the recruitment system.

7. Data quality

We take reasonable steps to keep the Personal Data we possess accurate and to delete incorrect or unnecessary Personal Data. We encourage you to access your Personal Data through your account from time to time to ensure that it is up to date. To the extent permitted or required by applicable local law or subject to your consent, we may use public sources in order to verify that Personal Data we hold is correct.

8. Contact

If you want to exercise your rights or have questions in relation to our privacy practices you may make a request in writing at privacy@otainsight.com.

OTA Insight will respond to your request within a reasonable timeframe.

Please be aware that depending on the circumstances, if you request us to delete or otherwise stop processing your Personal Data, we may not be able to proceed with your application, as it may depend on the analysis of such Personal Data.