Introduction
Black Swan respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you apply for a role and tell you about your privacy rights and how the law protects you.
Purpose of this privacy notice
This privacy notice aims to give you information on how Black Swan collects and processes your personal data when applying for a role with us. This process is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy notices, policies or fair processing policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.
Controller
Black Swan is made up of different legal entities, including Black Swan Hungary Kft (Hungary), Black Swan Data, Inc. (United States of America), Black Swan Avionics Limited (England & Wales), Black Swan Trends Limited (England & Wales), and Black Swan Innovate Limited (England & Wales). This privacy notice is issued on behalf of the Black Swan Group so when we mention ”COMPANY”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Black Swan Group responsible for processing your data. We will let you know which entity will be the controller for your data when you engage with us. Black Swan Data Ltd is the controller and responsible for the application process.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy notice, our privacy practices or wish to exercise your privacy rights, please contact our DPO in the following ways:
Full name of legal entity: Black Swan Data Ltd
Email address: dpo@blackswan.com
Postal address: DPO, Black Swan, 5th Floor, The Tower Building, 11 York Road, London SE1 7NX
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this notice and your duty to inform us of changes
We keep this privacy notice under regular review and will update it when necessary. We will not inform you of these changes unless we change why we are processing your personal data, what we need, why we need it or what we do with it.
It is important that you return to review this notice regularly to ensure that you are aware of any changes that we have made. It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Links to other websites
Where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.
Purpose and legal basis for processing
Our purpose for processing this information is to assess your suitability for a role you have applied for.
The legal basis we rely on for processing your personal data is article 6(1)(b) of the GDPR, which relates to processing necessary to perform a contract or to take steps at your request, before entering a contract. The legal basis we rely on to process any information you provide as part of your application which is special category data, such as health, religious or ethnic information is article 9(2)(b) of the GDPR, which also relates to our obligations in employment and the safeguarding of your fundamental rights and article 9(2)(h) for assessing your work capacity as an employee. And Schedule 1 part 1(1) and (2)(a) and (b) of the DPA2018 which relates to processing for employment, the assessment of your working capacity and preventative or occupational medicine.
What will we do with the information you give us?
We’ll use all the information you provide during the recruitment process to progress your application with a view to offering you an employment contract with us, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide with any third parties for marketing purposes.
We’ll use the contact details you give us to contact you to progress your application. We’ll use the other information you provide to assess your suitability for the role.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not keep it longer than necessary.
The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for, but it may affect your application if you don’t.
Application stage
If you use our online application system, your details will be collected by a data processor on our behalf (please see below).
We ask you for your personal details including name and contact details. We’ll also ask you about previous experience, education, referees and for answers to questions relevant to the role. Our recruitment team will have access to all this information.
You will also be asked to provide equal opportunities information. This is not mandatory – if you don’t provide it, it won’t affect your application. We won’t make the information available to any staff outside our recruitment team, including hiring managers, in a way that can identify you. Any information you provide will be used to produce and monitor equal opportunities statistics.
Shortlisting
Our hiring managers shortlist applications for interview. They will not be provided with your equal opportunities information if you have provided it.
Assessments
We may ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; attend an interview; or a combination of these. Information will be generated by you and by us. For example, you might complete a written test, or we might take interview notes. This information is held by us.
If you are unsuccessful after assessment for the role, we may ask if you would like your details retained in our talent pool. If you say yes, we would proactively contact you should any further suitable vacancies arise.
How long is the information kept for?
Whether you are successful or unsuccessful in your application, we will keep your personal data as part of this process for one (1) year.
How we make decisions about recruitment
Final recruitment decisions are made by hiring managers and members of our recruitment team. We take account of all the information gathered during the application process.
Any online testing is marked, and a result is generated automatically. However, if you wish to challenge the mark you have received, the result can be checked manually.
You can ask about decisions on your application by speaking to your contact in our recruitment team.
Do we use any data processors?
Yes, your personal data will be shared with Greenhouse Software, Inc., a cloud services provider located in the United States of America and engaged by us to help manage our recruitment and hiring process on our behalf. Accordingly, if you are located outside of the United States, your personal data will be transferred to the United States. Because the European Union Commission has determined that United States data privacy laws do not ensure an adequate level of protection for personal data collected from EU data subjects, the transfer was subject to appropriate additional safeguards under Privacy Shield.
We require third parties to respect the security of your personal data and to treat it in accordance with the law.
International processing
We will process your personal data within the Black Swan Group. This will involve processing your data outside the European Economic Area (EEA). We will process your personal information from our offices in the UK, USA, EU and South Africa.
Data security
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 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. Details of these measures may be obtained from our Data Protection Officer.
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.
Your rights
As an individual, you have certain rights regarding your own personal data.
Your right of access
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about this right here.
Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here.
Your right to erasure
You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right here.
Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here.
Your right to object to processing
You have the right to object to processing if we can process your information because the process forms part of our public tasks or is in our Legitimate Interests. You can read more about this right here.
Your right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about this right here.
If we are processing your information for criminal law enforcement purposes, your rights are slightly different. Please see the relevant section of the notice.
You are not required to pay any charge for exercising your rights. We have one month to respond to you. Please contact our DPO if you wish to make a request.
Acknowledgement/ Acceptance of Privacy Notice
By applying for this role, please confirm that you have read and agree to the Black Swan Data Ltd recruitment privacy notice pertaining to the processing of your candidate data.
