Kin and Carta Candidate Privacy Notice

About this Privacy Notice

Kin and Carta Plc (being the parent of the wider organisation), Kin and Carta UK Limited, Kin and Carta Partnerships Limited and Melon EAD, Melon Tehnologii, and Frakton (collectively referred to as ‘Kin + Carta’, ‘we’ or ‘us’), recognise themselves as joint controllers of your personal data as the recruitment process and any subsequent employment/engagement contract are key purposes of the collection of the data outlined below and the activities associated with this could be directed by these businesses jointly or alone. This means that these businesses may decide how to process your personal data. Usually this will be the business which you are applying for a role with, however there are circumstances where the other businesses may provide a service or support which requires them to abide by this Privacy Notice. This could be human resource support which is organised by one Kin + Carta business and extended to another.

How to contact us

You can get in touch with us in any of the following ways:

By email: data.protection@kinandcarta.com

Via these websites:

https://www.kinandcarta.com/

https://melontech.com/

https://frakton.com/

This Privacy Notice relates to personal data collected by us during the recruitment process. We may collect and process this information in a variety of ways. For example, data might be contained in application forms, covering letters, resume or curriculum vitaes (CVs) (including when these are sent to us as part of speculative applications or queries), obtained from your passport or other identity documents, or collected through interviews or other methods of assessment during your interactions with us, our agents or partners. We could collect personal data via:

• Our websites
• Third party recruitment partner or job-board websites
• During interviews, tests or assessments
• Paper or digital correspondence including telephone or video calls
• Visiting our offices
• Your named referees, previous employers, educational, examination or certification bodies 
• Background check providers including credit checking, governmental, regulatory for law enforcement agencies
• Data which is publicly available on the internet
• By any means in which you provide us with your personal information

What data we process about you

Kin + Carta may collect and process the following categories of personal data about you:

Contact Details

• Name, address, age, date of birth and contact details, including email address and telephone number

National identifiers

• Nationality/ies, national IDs/passport, social security / insurance numbers, place of birth, immigration information, your entitlement to work in the countries you are seeking employment/engagement/work in and visa status  

Experience Information

• Details of your qualifications, skills, experience, employment history (including previous employers, job titles, or positions), and current level of remuneration, including benefit entitlements

Equal opportunities monitoring information

• Information about your physical and mental ability, gender, ethnic origin, sexual orientation, health, religion or belief(s)

Application information

• Information concerning your application and our assessment of it. This could include financial information and information on benefits received. 

Tests or assessments 

• Any tests or assessments you may complete for us as part of the recruitment process as well as our assessment of it

Criminal record information

• Information regarding any criminal record you may have

Referee details and feedback 

• Information from previous employers or referees 

Social Media 

• Any publicly available information available online including social media and professional sites such a linkedin

Recording

• CCTV images and recording of interviews. 

We may collect any other information you voluntarily provide throughout the process, including online, through interviews or other forms of assessment.

We use legitimate interest as our main legal basis for the processing of your application, however we may also use the legal and/or consent as a basis where it is required or is more suitable.

The purpose(s) for which we will collect and process your data are shown below:

• To manage and undertake the recruitment process, including assessing and confirming a candidate's qualification, skills and suitability for employment/engagement and deciding whom to offer a job
• To carry out background and reference checks, where applicable
• To respond to and defend against legal claims
• To comply with our legal obligations
• To make reasonable adjustments for candidates who have a disability
• To comply with our equal opportunities monitoring purposes
• To enter into a contract of employment/engagement with you once you accept the job offer

How we use sensitive personal information

We will use your sensitive personal information in the following ways:

We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether appropriate adjustments need to be made during a test or interview or to the work environment.

We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions and background checks

If we would like to offer you a role (conditional on checks and any other conditions, such as references, being satisfactory), we might collect information about your criminal convictions history and perform a background check. You will be informed prior to such a check being undertaken.

Data sharing

Your information may be shared internally within the Kin + Carta Group (which refers to Kin and Carta plc and all its subsidiaries) for the purposes of the recruitment process.

We may also share your data with third parties which are connected with the recruitment process or the general running of our business, these may include:

• Recruiters or recruitment agencies 
• Background checking organisations including credit reference agencies or criminal record checks 
• Previous employer or other referees
• Our clients or investors 
• Education, certification or examination bodies
• Regulators, law enforcement or government agencies.

We require third parties to respect the security of your data and to treat it in accordance with the law. We may also disclose your personal details if  a third party acquires us, a member of the Kin + Carta Group or substantially all of our assets.

International Transfer of Data

As a global organisation headquartered in the UK with offices and workers across Europe, Latin America, and the United States, we may transfer your personal information outside the territory you are resident in. This may include members of our HR team, interviewers or third parties involved in the recruitment process, other recruitment decision-makers in the Kin + Carta Group, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. 

Your data will be processed in the UK and EU, however Kin + Carta may transfer your data outside of these regions to countries such as Argentina Colombia, Kosovo, North Macedonia, USA or other locations where the Kin + Carta Group carries out its business. Where these transfers take place they will either be to countries that are adequate in the view of the EU and/or UK or Standard Contractual Clauses will be used to ensure appropriate safeguards are in place. 

Representation

• Our representative within the EU is Kin and Carta Greece (Μονοπρόσωπη Ι.Κ.Ε.) 
• Our representative within the UK is Kin and Carta UK 

Both can be contacted via data.protection@kinandcarta.com.

Retention and destruction of personal information

We will only retain your personal information for as long as necessary to fulfil any legal requirement and the purposes we collected it for. 

If your application for employment/engagement is unsuccessful (including when you have speculatively applied to us in respect of a role which is not available), we will hold your data on file for up to 24 months in case there are future employment/engagement opportunities for which you may be suitable for you. At the end of that period, your data is deleted or destroyed (unless we need to retain it for longer to exercise or defend any legal claims). 

You are free to request we delete your data at any time, this can be requested via data.protection@kinandcarta.com.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

If your application for employment/engagement is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment/engagement. The periods for which employee/contractor/worker data is held will be provided to you in a separate privacy policy.

Your Rights

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. 

You are under no statutory or contractual obligation to provide data to Kin + Carta during the recruitment process. However, if you do not provide the information, we may not be able to process your application.You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

You also have the rights and choices which you can exercise on the data we hold on you.

You have the right to:

• Obtain access to your personal information
• Withdraw consent
• Object to direct marketing
• Ask us to correct any errors or delete the information we hold
• Object or restrict our processing of your information
• Request that we port your personal information
• Not to be subject to decision based solely on automated processing

The right to raise a complaint with a data protection authority which in the UK is the Information Commissioner's Office (https://ico.org.uk/) and in the EU can be located from this list (https://edpb.europa.eu/about-edpb/about-edpb/members_en) 

For more information or to action these rights, please contact us on data.protection@kinandcarta.com

Security

The transmission of data over the internet is not completely secure. Kin + Carta takes the security of your data seriously and we will do our best to protect your personal information, however, we cannot guarantee its security. 

Once we have received your data we will use strict internal security measures and controls to try to protect it against loss, misuse, or unauthorised alterations. 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.

Data Protection Office

If you have concerns that you would like to raise with us, please contact our Data Protection Office: data.protection@kinandcarta.com

If you have any questions about this Privacy Notice, want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact data.protection@kinandcarta.com. 

If you are unhappy with how we process your personal data, you may have the right to complain to a data protection regulator or supervisory authority. We encourage you to contact us in the first instance so we can address your concerns.

Changes to this Privacy Notice

This Candidate Privacy Notice is dated August 2022. We reserve the right to amend this Privacy Notice at any time without notice, in which case the date of the policy will be revised.