1. Introduction
Worldreader is committed to protecting the privacy and security of your (“you” or “Candidate”) personal data. As your prospective employer/entity engaging you, we need to collect personal data about you and we are a “controller” of it under data protection law.
This notice is to help you understand what personal data we collect about you in the course of recruitment, why we collect it and what we do with it. By “you”, “your” or “Candidate” we mean you the candidate or job applicant.
2. Who we are
Worldreader.org is an international group of non-profit organizations that champions digital reading in underserved communities to create a world where everyone can be a reader (“Worldreader Group”).
Worldreader Group comprises the following, legally independent, entities:
United States
Worldreader.org, a 501(c)3 charity (EIN-27-2092468), incorporated in the State of Washington and main operations office in 1211 Folsom St 4th Floor, San Francisco, CA 94103.
Spain
Fundación Worldreader.org, registered as a Foundation under the Ministry of Education (Registration number 1361), with its registered address at Calle Mallorca 318, 3º 1ª, 08037, Barcelona.
United Kingdom
Worldreader, a Charitable Incorporated Organisation under the Charity Commission (Registered Charity Number 1158030), with registered office at 20 Dartmouth Park Road, London NW5 1SX.
Ghana
Worldreader.org, a Private Company limited by Guarantee (Registration Number DSW 5568), with principal offices located at East Legon, Nii Amoo Lane, Ghana Post GPS Address GD-209-0819.
Kenya
Worldreader, an International NGO (Registration number OP.218/051/13-0274/10902), with registered office at Cathy Flats No. 8, Lenana Road, Kilimani Area, Nairobi.
India
Digital Reading Foundation (DRF), a Company limited by shares and not for profit (CIN U74900DL2015NPL288080), with registered address at House No. B 242, Lower Ground Floor, Greater Kailash, Part-I, New Delhi – 110048, Delhi.
“We”, “us”, “Worldreader” are references to Worldreader.org, which is the data controller of your personal data for the purposes described in this Workers Privacy Notice.
If you have any questions or concerns regarding this Recruitment Privacy Policy or our processing of your personal information, or you want to exercise any of your rights in accordance with the applicable regulations, please us by e-mail at privacy@worldreader.org, through our telephone number +34 930 131 276 or by post mail at the address of the entity listed above that you are applying to work for or collaborate with.
3. How we collect your personal data
This information is either:
- provided directly by you when you apply for a role with us, during your interactions with us ( e.g. interviews, and other exchanges) and/or in the course of assessments for that role;
- obtained from third parties such as recruitment agencies (i.e. BambooHR), job placement services (i.e. LinkedIn) or an internal Worldreader contact when you are being recommended for consideration for a role; or
- created by us in the course of the recruitment process.
4. What personal data we collect about you
We collect, store, and use the information below about you during the recruitment process. If you fail to provide certain information when requested we may not be able to progress your application.
- information we require according to local labour law when recruiting for job position, including: name(s) and surname, name of parents (if minor), date of birth, place of residence, correspondence address, education, course of previous employment;
- information we receive from you when applying/recruiting for a job position, including: name(s) and surname, date of birth, gender, place of residence, correspondence address, citizenship, education, information on previous employment;
- information provided in your curriculum vitae, application form and during the interview process including: your name, date of birth, age, gender, home address, personal email address, education, qualification and work experience details, references, training, diplomas, knowledge of foreign languages, data on the possession of driving licenses, data contained in employment certificates, data collected during the interview and financial expectations;
- information collected or created by us during the recruitment process including: interview notes and correspondence between us;
- information about criminal convictions[1]: to the extent allowed under applicable law, we may carry out background checks as part of the recruitment process; and
5. How we use personal data
We will use your personal data (including special categories of personal data) where permitted by law, which means that we need a legal basis in order to process it, which includes the following:
- to progress the recruitment process, assess and make a decision about your suitability for a role, and to communicate with you;
- to carry out reference checks, pre-employment/engagement checks and background screening where relevant, and to undertake any steps that we need to take prior to employment/engagement;
- to comply with legal and regulatory requirements;
- where you have provided your consent to use your data, where relevant;
- where it is necessary for the establishment, exercise or defence of legal claims;
- where it is necessary for our legitimate interests (or those of a third party) provided that our or a third party’s legitimate interests are not overridden by your interests or fundamental rights which require protection of your data;
- exceptionally, if it is necessary for vital interests relating to you or another person (for example, avoiding serious risk of harm to you or others) and where you are not capable of giving consent (when consent is required); and
- where it is needed for reasons of substantial public interest, provided that it is based on the applicable law regulations, such as for equal opportunities monitoring.
6. Why we use personal data
We will use your personal data, as it is our legitimate interest as a recruiter to fully understand, identify and assess the suitability of potential candidates or applicants for a role and verify the information provided to us. We are also under a legal obligation to perform checks around your legal right to work.
This means we will:
- Review and assess any information you provide in your job application to establish whether to progress it, contact you to arrange interviews and assessments, to evaluate your performance and provide feedback, and where successful to make you an offer and provide you with your contract of employment/engagement or other similar contract;
- where relevant, to carry out pre-employment/engagement checks and background screening[1] (including criminal record (to the extent we are allowed to perform such checks under applicable laws), to check your legal right to work, to verify the information in your CV and the references that have been provided to us. It is necessary for us to do so before entering into a contract of employment/engagement with you;
- perform search activities to identify opportunities, solicit names of potential candidates for specific (or potential) roles we are (or may be) recruiting for and contact such candidates; and
- perform market research activities in relation to recruitment.
7. Why we use special categories of personal data
During the recruitment process we may come across and capture special categories of personal information about you especially if you provide such information to us via your CV or our recruitment agency (i.e. BambooHR) or during our interviews/meetings. We may also need to process special categories of personal information about you (e.g. information about your physical or mental health) to ensure that we comply with our legal and regulatory obligations and in order to make any reasonable and necessary adjustments to enable you to participate in the recruitment process e.g. apply for a job, attend an interview or take an assessment. If you are successful, we will process special categories of personal information during onboarding and thereafter to ensure all necessary arrangements are made for when you join us. We may also process information relating to criminal convictions and offences as described in the next section.
8. Information about criminal convictions
Where appropriate[1], as part of the recruitment process we may ask you for information in relation to criminal convictions and/or we may carry out criminal background checks.
We use this information about criminal convictions and these checks in the following ways:
- to protect your interests, our interests and third party interests. Third parties include Worldreader staff and beneficiaries of our activities, comprising children and vulnerable adults;
- because it is necessary in relation to legal claims. We are allowed to use your personal information in this way where it is necessary to carry out our employment/engagement rights and obligations.
We will only process information relating to criminal convictions and offenses when necessary for the above purposes and where we have obtained your explicit consent (where required) or where we are permitted to do so by applicable laws.
9 . Who we share your personal data with, why and how
During the recruitment process, we will need to share your personal information internally and with certain third parties. Any information that we share either internally or externally is only limited to what is required by each party or individual to perform their role in the recruitment process and could involve the following:
Internally:
- recruiting and other relevant managers of Worldreader Group;
- individuals within the HR department who are involved in certain aspects of the HR processes;
- IT and relevant areas to ensure access to relevant systems;
- security, reception and facilities, where appropriate;
Externally:
- recruitment agencies and candidate interview and assessment service providers, such as BambooHR;
- pre-employment/engagement screening and background check providers (if applicable) (e.g. criminal checking providers etc.)[1];
- academic institutions, professional bodies, regulators and competent authorities to the extent required by the applicable laws;
- entities, companies or individuals you worked for in the past for validation and/or reference purposes; and
- other third-party suppliers who provide services on our behalf.
10. Where your personal data is held or transferred to
We are a member of the Worldreader Group and your personal data may be transferred to countries where companies, organisations and individuals inside and outside of Worldreader Group that we share data with are located. Data protection laws vary by country and those applicable in the EU and elsewhere are not equivalent to those applicable in certain other jurisdictions. Worldreader will take steps to protect your personal data in line with the applicable data protection requirements. Some of the mechanisms we use include the adoption of Standard Contractual Clauses (SCCs) approved by the European Commission. However, we inform you that the human resources information system that we mainly use to store and manage your data – BambooHR LLC – has been certified under the EU-US Privacy Shield Framework for both Human Resources and non-Human Resources data.
11. How we protect your personal data
We follow strict security procedures as to how your personal data is stored and used, and who sees it, to help stop any unauthorised person accessing it. Our Global Data Privacy Rulebook sets out the standards we follow to keep your information secure. When information is kept by other parties providing a service to us, they are expected to adhere to standards set by Worldreader and by the relevant law. For further information, please refer to our Global Data Privacy Rulebook.
12. How long we keep hold of your data
We will only retain your personal data for as long as permitted by applicable law or necessary to fulfil the purposes we collected it for.
We will retain your personal information for the duration of the recruitment process in connection to the position you applied for and we may retain and use your personal information to consider you for other positions if you have consented to this. We will also hold some personal information about you as required for legal or regulatory purposes and for the length of any applicable limitation period for claims which might be brought against us later. If you are successful in applying for a position, your personal information will be retained for the purposes of your employment/engagement with us, as set out in our Workers Privacy Notice.
We will use reasonable endeavors to remove your records from our systems three (3) years from the moment we first process your data to consider your candidacy or application for a role.
Where appropriate we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will use secure methods to delete or destroy your personal data.
13. Your data protection rights and how to exercise them
As data subject, you have certain rights in relation to our handling of your data. These include the following:
- Request Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal data (commonly known as a “data subject rights / 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: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
- Request Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances (e.g., if you withdrew your consent to process your personal data for specified therein purposes) where there is no good reason for us to continue processing it. There are also certain occasions where we may refuse a request for erasure, for example, where the personal data is required for compliance with laws and regulations, with our obligations under our employment/engagement and for other legal reasons;
- Request Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
- Request Transfer: you may request the transfer of certain of your personal data to another party; and
- Object to processing: where we are processing your personal data based on a legitimate interest (or those of a third party) and there is something about your particular situation you may object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. However, we may be entitled to continue processing your information based on our legitimate interests.
If you 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 us in writing at privacy@worldreader.org.
We sometimes need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). Therefore, we may also need to retain some information if you submit one of these requests, in order to fulfil it. If you do not give us the specific information that we require or give us inaccurate data, we may not be able to perform your request.
14. Right to withdraw consent
In the limited circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at privacy@worldreader.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. The withdrawal only applies to any future processing not what we have done in the past.
15. Right to complaing before a supervisory authority
If you think we have processed your personal information unfairly or unlawfully, you have a right to lodge a complaint with the data protection authority, in particular in the Member State in the European Union where you are habitually resident, where you want to work or where an alleged infringement of Data Protection law has taken place. A list of all the data protection authorities within European Union region may be found under the following link: https://edpb.europa.eu/about-edpb/board/members_en.
In Spain, complaints about how we process your personal information may be submitted to the Spanish data protection authority – Agencia Española de Protección de datos (AEPD), which can be contacted using the following details:
Agencia Española de Protección de Datos (AEPD)
C/Jorge Juan, 6, 28001, Madrid
Tel. +34 91399 6200
Fax +34 91455 5699
E-mail: internacional@agpd.es
Website: https://www.aepd.es/
Please note that, if you have a concern about how we have processed your personal data, many data protection/privacy regulators will ask that you contact us first, outlining your concerns, and give us the opportunity to put the issue right, prior to contacting them with your complaint or concern.
16. Changes to this notice
This notice may be changed from time to time. The current version of this Recruitment Privacy Notice will be posted on our website.
If you have any questions about this Recruitment Privacy Policy, please contact us at privacy@worldreader.org.
Last update: 15 of June 2020
