SHAWCOR RECRUITMENT PRIVACY NOTICE - SHAWCOR UK Ltd.

(PROCESSING OF PERSONAL DATA IN THE CONTEXT OF JOB APPLICATIONS)

1. Introduction

This privacy notice describes how we collect and use your personal data when you apply for a job at Shawcor.

Your personal data is collected and processed by Shawcor UK Ltd.

If you apply for a job via our website shawcor.com, your personal data is also collected and processed by our corporate headquarters in Canada, Shawcor Ltd. ("we"/"us"/"our"/”Shawcor”). This is for the purposes of managing a centralized recruitment database, ensuring general governance at group level and for support (including regarding IT). Shawcor UK Ltd. and Shawcor Ltd. are joint-controllers for job applications processed through shawcor.com and subsequently flowing into our recruitment tool, SuccessFactors.

If you have any questions or complaints in relation to the use of your personal data or if you would like to receive more information on the processing of your personal data by Shawcor, please contact us via privacy@shawcor.com.

2. Type of personal data collected

During the recruitment process, we collect, store, and use the following personal data about you.

(i) When you apply for a job at Shawcor via shawcor.com:

  • Details of your account at shawcor.com, including name and e-mail address.
  • Personal data collected through the application form, including personal data in your curriculum vitae and covering letter, and name, e-mail address, telephone number, home address, salary range, references, information on education, language skills, qualifications and professional development.
  • Personal data collected or created by us during the recruitment process including a summary spreadsheet of you as an applicant, interview notes and correspondence between us.

(ii) When you apply for a job via e-mail:

  • Personal data included in your curriculum vitae and covering letter, which may include your name, date of birth, home address, e-mail address, telephone number, education, language skills, qualifications, and work experience details.
  • Personal data collected or created by us during the recruitment process including a summary spreadsheet of you as an applicant, interview notes and correspondence between us.

(iii) When you apply for a job at Shawcor via an external recruitment agency (SPS-division only):

  • Personal data included in your curriculum vitae, which may include your name, date of birth, education, language skills, qualifications, and work experience details.
  • Agency’s description of you as a candidate.

In addition to the above, all prospective individuals are subject to pre-employment alcohol / drug screening in accordance with Shawcor’s Substance Misuse Policy. In this context we may collect samples and process screening results. Any offer of employment is subject to a negative screen, and Shawcor retains the right to withdraw any offer for violation of this policy.

This information may include personal data relating to your health. Shawcor may process this information as it is necessary for the performance of its obligations under employment, social security and social protection laws (article 9(2)(b) GDPR in combination with paragraph 1, Schedule 1 of the Data Protection Act 2018).

You are not obliged to provide us your personal data, but if you choose not to do so we cannot process your application.

3. Sources of personal data

This personal data is (i) provided directly by you; (ii) created by us in the course of the recruitment process, and/or (iii) provided to us by third parties involved in the application and recruitment process, including former employers, and external recruitment agencies (Shawcor UK, Ltd., SPS-division only). As regards recruitment agencies, our SPS-division frequently works with the following agencies: P&S Personnel Ltd., IRS Recruitment, Cooper Lomaz and Premier Engineering.

4. Why we process your personal data and the applicable legal basis

We process your personal data to administer, progress and manage the recruitment process, to assess your suitability for a job at Shawcor, to follow up on applications and/or communicate with you, to carry out reference checks, and to monitor compliance with our Substance Misuse Policy.

We process the personal data collected from you because:

  • it is necessary for us to do so before entering into a contract with you;
  • we need to comply with our legal and regulatory obligations; and
  • we or a third party have a legitimate interest to, which include (a) ensure the effective administration and management of the recruitment process; (b) ensure we hire a suitable individual for a role; (c) deal with disputes and accidents and take legal or other professional advice; and (d) ascertain your fitness to work.

Any sharing of personal data within our group of companies - particularly our corporate headquarters in Canada, Shawcor Ltd. – is necessary for our legitimate interest to ensure effective and consistent management of job applicants at group level, general governance at group level, and corporate support throughout Shawcor (including regarding IT).

5. Sharing of your personal data

To the extent applicable, we will disclose or share your personal data to / with the following third party:

  • Party - SAP
  • Purpose - the provider of our company wide recruitment application SuccessFactors

For the purposes of maintaining and managing a centralized recruitment database, ensuring general governance at group level, and for support (including regarding IT), your personal data will also be shared with and processed by our corporate headquarters, Shawcor, Ltd.

We may also share your personal data with regulators and competent authorities.

6. Retention of your personal data

We do not process your personal data any longer than necessary for the processing purpose (i.e. to administer the recruitment process).

If we are subject to a statutory retention period, we will retain your personal data for the period specified by the law.

We may also retain your personal data for the length of any applicable limitation period for claims that might be brought against us later (i.e. six years in the UK).

If you are offered a position at Shawcor, your personal data will become part of your employment file and retained for the period specified in our employee privacy notice.

7. Where your personal data will be held

Your personal data is stored on (local) servers in the United Kingdom and backed-up to servers in Frankfurt (Germany).

For transfers of personal data to Shawcor, Ltd. the following applies. Shawcor, Ltd. is located in Toronto, Canada. The European Commission has determined that Canada offers an adequate level of data protection (please see here). This means that your personal data will be subject to a level of data protection similar to that in the United Kingdom, and, as a consequence, personal data may flow to Shawcor, Ltd. without additional safeguards being necessary.

In case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR) (or such other clauses as may be approved by the authorities in the United Kingdom). For more information on these Standard Contractual Clauses, please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions of the European Commission (or such other adequacy decisions adopted or approved by the authorities in the United Kingdom). For more information on adequacy decisions, please see here.

8. Your rights

You have the right to access your personal data, the right to have your personal data rectified or erased, the right to restriction of the processing, the right to data portability and the right to object to the processing. Most of these rights are not absolute and are subject to exemptions in the law.

Below we set out your rights in more detail and give information on how you can exercise these. We will respond to your rights request within one month, but we have the right to extend this period up to a maximum of three months where the request is complex or there are a number of requests. If we extend the response period, we will let you know within one month from your request.

  • Access: you are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If your request is clearly unfounded or excessive we reserve the right to charge a reasonable fee or refuse to comply in such circumstances.
  • Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
  • Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with legal claims.
  • 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.
  • Data portability: you may request the transfer of certain of your personal data to you or another party. You have the right to ask that we provide your personal data in an easily readable format to another company.
  • Objection: where we are processing your personal data based on a legitimate interest (or those of a third party), you may object to processing on this ground. However, we may be entitled to continue processing your personal data based on our legitimate interests.

If you have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent at any time. Please note that the withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.

If you want to exercise any of these rights, or withdraw your consent, please contact us via privacy@shawcor.com. Alternatively, you may logon to your account (if applicable) and access, correct or erase your personal data.

9. Right to lodge a complaint with a supervisory authority

If you have any complaint about the way we process your personal data, you may lodge a complaint with a supervisory authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. The competent supervisory authority for the United Kingdom is the Information Commissioner’s Office (helpline +44 303 123 1113 or https://ico.org.uk/make-a-complaint/).

10. Changes to this privacy notice

Shawcor may change this Recruitment Privacy Notice from time to time.

If we make any important changes to this Recruitment Privacy Notice (e.g. with regard to the personal data we collect, how we use it or why we use it), we will notify you.

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