Candidate Privacy Notice

Trailstone UK Ltd. and Trailstone Renewables GmbH (“Trailstone”) are “data controllers". This means that we are responsible for deciding how we hold and use personal information about you. You are seeing this privacy notice because you are applying for work with Trailstone (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of recruitment, and how long it will usually be retained. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR)), and the UK General Data Protection Regulation (UK GDPR).

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as is necessary for the purposes we have told you about; and
• kept securely.

The kind of information we hold about you

In connection with your application for work with Trailstone, we will collect, store, and use the following categories of personal information about you:

• The information you have provided in your curriculum vitae, covering letter and any other correspondence between us;
• The information you have provided to the recruitment agency, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, education history and compensation history;
• Any information you provide to us during an interview;
• Feedback and comments from the interview process.

Where relevant, we may also collect, store and use information about your health, including any medical condition, health and sickness records.

How is your personal information collected?

We collect personal information about candidates from the following sources:

• You, the candidate.
• Recruitment agencies.
• Your named referees.

How we will use information about you

We will use the personal information we collect about you to:

• assess your skills, qualifications, and suitability for the role;
• carry out background and reference checks, where applicable;
• communicate with you about the recruitment process;
• keep records related to our hiring processes;
• comply with legal or regulatory requirements; and
• decide whether to enter into a contract of employment with you.

It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application, we will not be able to process your application successfully.

How we use particularly sensitive personal information

We may use your particularly sensitive personal information (e.g. about your disability status) to consider whether adjustments need to be made during an interview or in your employment.

We do not envisage that we will process information about criminal convictions during the application process.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

Why might you share my personal information with third parties?

We will only share your personal information with third parties for the purposes of processing your application. 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 and in accordance with our instructions.

UK - EEA

Where we receive data from an EEA counterparty into the UK we will operate to the EU GDPR standards. We use Standard Contractual Clauses (SCCs) to ensure we are in compliance with both EU and UK GDPR standards.

Data security

We have put in place appropriate security measures to prevent your personal information 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.

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 required to do so.

Data retention

How long will you use my information for?

We will retain your personal information for a period of three years after we have communicated to you our decision about whether to appoint you to the role.  After this period, we will securely destroy your personal information in accordance with our data retention policy. If you are engaged or employed by Trailstone, this privacy notice shall by superseded by the Trailstone privacy notice for employees, workers, contractors and consultants.

We 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 also retain your personal information because we have a legitimate interest in the event that your profile is suitable to another job vacancy in the future.  If you do not want us to hold your personal information for this purpose, you have the right to object, in which case we will remove your personal information from our records.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law 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.

If you want to review, verify, correct or request erasure of your personal information or object to the processing of your personal data, please contact Compliance in writing at compliance-europe@trailstonegroup.com.