Job Applicant Privacy Notice - Orla

Contents

Purpose
Who We Are
What information do we collect?
Why do we process personal data?
Who has access to data?
How do we protect data?
AI in Recruitment
Transfers outside of the UK or EEA
For how long do we keep data?
Your rights
Consequences of not providing personal data
Automated decision-making
Changes to this Privacy Notice
Getting in touch about your rights
Complaints about how we handle your information

Purpose

This privacy notice describes how we collect and use personal information about you during the recruitment process, in accordance with the EU General Data Protection Regulation (GDPR) and applies to all candidates.

This Privacy Notice is for information only; it is not a contractual agreement.

Who We Are

Orla Living Limited, Orla Living S.r.l. and Orla Living S.l. are Managing Agents for student, flexible and later living. Please see company details below:

Orla Living Limited

Registered Office Address:

3rd Floor,

40 Mespil Road,

Dublin 4,

D04 C2N4,

Ireland

Company Registration Number: 785141

Orla Living S.r.l.

Registered Office Address:

Largo Richini, 6,

20122,

Milan,

Italy

Codice Fiscal/Company Registration Number: 14669790967

Orla Living S.l.

Registered Office Address:

Paseo de Recoletos, 5,

Madrid,

28004,

Spain

NIF (Número de Identificación Fiscal)/Company Registration Number: B26582916

Main website: https://orla-europe.com/

Our brand websites are as follows:

Orla Student: https://orla-student.com/

Orla Living: https://orla-living.com/

Orla Life: https://orla-life.com/

Heydey: https://heydayatcarmanshall.com/

What information do we collect?

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

the information you have provided to us in your curriculum vitae and covering letter/email;
any information you provide to us during an interview;
information you provide during onboarding including ,:-
- information required to complete Right to Work (where applicable);
- DBS screening (a criminal record check)
- a credit check
- reference and background checks such as prior employment, regulatory body checks and certificate checks.

In certain circumstances, we may check your LinkedIn, other business-related account or your public profile.

We may also collect, store and use the following “special categories” of more sensitive personal information:

information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
information about your health, including any medical condition, health and sickness records; and
information about your criminal record.

We may collect personal information from the following sources:

you, the candidate;
recruitment agencies;
search consultants;
our employment background check provider;
our credit reference agency;
your named referees; and
data from third party publicly accessible sources. For example, professional memberships, LinkedIn, publicly available information on social media.

If you apply for a role with us via our online candidate portal, then your information will be provided to us through that portal which is securely hosted by a third-party provider.

Why do we process personal data?

We need to process data to take steps at your request, prior to entering into a contract with you. We also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal and regulatory obligations. For example, we are required to check your eligibility to work in the EU before employment starts

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from you allows us to manage the recruitment process, assess and confirm your suitability for employment and decide to whom to offer a job. We may also need to process data from you to respond to and defend against legal claims.

We process health information if we need to make reasonable adjustments to the recruitment process for you. This is to carry out our obligations and exercise specific rights in relation to employment.

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes. The provision of equal opportunities monitoring information is optional. We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. We use a third party to do this on our behalf and may receive a copy of their report if you have consented for us to do so.

We will not use your data for any purpose other than the recruitment exercise for which you have applied.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy if access to the data is necessary for the performance of their roles.

If you make an application through our candidate portal online, your data is held within that third party system. The third-party provider does not have direct access to your data but there may be limited occasions where, in order to investigate a support ticket, the supplier may need to be granted access.

We will not share your data with other third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, our employment background check provider to obtain necessary background checks, including a criminal record check and our credit reference agency. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.

How do we protect data?

We take the security of your data seriously. 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 legally required to do so.

AI in Recruitment

Applicants for any vacancy are entitled to use AI to support their research and assist in their own creation of a response to any application questions. However, all responses must be accurate and the final work of the applicant and not simply copied from AI or any other source.

Transfers outside of the UK or EEA

We do not envisage transferring the personal information we collect about you outside the EU during the recruitment process.

If we ever do need to transfer your data outside of the UK or EEA, to ensure that your personal information does receive an adequate level of protection, we will ensure that that there is an adequacy decision in respect of that country or will verify/put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU laws on data protection. Further details of this can be requested using the contact details below.

For how long do we keep data?

If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If we wish to retain your personal information on our candidate portal, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis. You are free to withdraw your consent at any time by contacting the DPO on the email address provided below. We may be required to keep your information longer however, for example if you proceed with a role with us. Further information can be obtained in the contact details below.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file. The periods for which your data will be held will be provided to you in our Employee Privacy notice which is available to all staff.

Your rights

As a data subject, you have a number of rights. You can:

access and obtain a copy of your data on request;
require us to change incorrect or incomplete data;
require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing; and
ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact the DPO at the contact details below.

Consequences of not providing personal data

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

If your application is successful, to cover our obligations under legislation and for legitimate business reasons it will be a condition of your contract that you complete satisfactory background checks.

You may be asked to provide information for equal opportunities monitoring purposes but there are no consequences for your application if you choose not to provide such information.

Automated decision-making

Our recruitment processes are not based solely on automated decision-making.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time.

Getting in touch about your rights

If you would like to enforce any of your rights, please submit your request via our secure portal here or contact our Data Protection Officer by email at: dataprotection@orla-europe.com or write to them at:

Orla Living Limited

3rd Floor,

40 Mespil Road,

Dublin 4,

D04 C2N4,

Ireland

Orla Living S.r.l.

Largo Richini, 6,

20122,

Milan,

Italy

Codice Fiscal/Company

Orla Living S.l.

Paseo de Recoletos, 5,

Madrid,

28004,

Spain

NIF (Número de Identificación Fiscal)/Company

Complaints about how we handle your information

If you believe that we have broken your data protection or privacy rights, you can complain to us via our secure portal here or via an email to our Data Protection Officer at: dataprotection@orla-europe.com.

If you are not happy with our response, or you want to contact the relevant Data Protection Authority (DPA), you can use the details below:

Ireland

Data Protection Commission

6 Pembroke Row
Dublin 2
D02 X963
Ireland

Telephone:

(01) 765 01 00

1800 437 737

Italy

Garante per la protezione dei dati personali

Piazza Venezia 11, 00187 Roma

Italy

Telephone:

+39 06.696771

Email:

protocollo@gpdp.it

Spain

Agencia Española de Protección de Datos – AEPD

C/ Jorge Juan, 6, 28001 Madrid,

Spain

Telephone:

+34 901 100 099

+34 91 266 35 17

If you have any questions about this privacy notice, please contact our Data Protection Officer: dataprotection@orla-europe.com.