GROUP GLOBAL RECRUITMENT PRIVACY STATEMENT

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU
Personal Data that we may collect, includes, but is not limited to:
- your name;
- date of birth;
- gender;
- national IDs /passport number/resident card numbers/social security numbers;
- marital status;
- copies of passport, employment pass / work authorisations and similar documents;
- contact details (such as telephone number, e-mail address and postal address);
- Curriculum Vitae/Resume;
- current and previous employment details (such as salary/bonus and employee benefits schemes);
- academic background (such as your university or school diplomas/certificates and other educational achievements);
- results of any pre-employment testing such as psychometric testing;
- immigration status and work permits;
- languages spoken and level of proficiency;
- job preferences including willingness to travel and/or relocate;
- any video/photo images or audio recordings that you submit to us in connection with your job application; and
- results of the selection and matching process and any other information which you decide to submit to us.

We do not generally seek to collect Sensitive Personal Data from you. In the circumstances where we do seek to collect such data or you voluntarily choose to provide us with this information as part of your application, we will Handle this information in accordance with applicable local data privacy laws. Sensitive Personal Data may include but is not limited to:
criminal records;
- racial/ethnicity information;
- trade union membership (if relevant in certain countries); and
- health related information including but not limited to physical/mental health status and benefits.

You may also wish to provide Sensitive Personal Data so that we can make reasonable arrangements during the recruitment process, for example to accommodate any disability. Your Sensitive Personal Data will not be used for any other purpose other than for your recruitment and/or your future employment with us.
We also Handle Personal Data provided by you regarding third parties if permissible by applicable local laws, when it relates to your application for employment with the Group such as details of your referees.

HOW DO WE COLLECT YOUR PERSONAL DATA
We collect your Personal Data in the following ways:
Our Careers Websites
We collect your Personal Data through your use of our Careers Site and our Graduate Recruitment Site and through any of our approved third party websites that we use for recruitment purposes (the “Websites ”). This includes but is not limited to Personal Data collected through:
- your submission of a job application through the Websites;
- your submission of your details to us via the Websites, for example, by creating or updating your profile and/or registering for job alerts; and
- your submission of any photo, video and sound recordings on the Websites in connection with your job application.
Social Network Sites
We collect your Personal Data from other sources, including LinkedIn, Facebook and Google+ (“Social Network Sites”) when you choose to provide us with a link to your profile on any Social Network Site as part of your job application or you elect to sign-in to the Websites via those Social Network Sites through the integrated functionality available on the Websites. If you sign-in to the Websites through Social Network Sites, we will collect your Personal Data from certain fields on these sites by taking a snapshot and merging this with other data captured through the online application form to create a single profile. In addition to the Personal Data set out above, we will collect the following Personal Data from Social Network Sites:
LinkedIn: Personal Data contained in the following fields: name, headline and summary, job title, current employer, employment history, recommendations and contact details made publicly available (such as phone number and email address). Your LinkedIn connections are not collected.
Facebook: Personal Data contained in the following fields: first name, last name, email, employer and job title. Your “likes”, “comments”, “friends lists/details” and “wall posts” are not collected.
Google+: Personal Data contained in the following fields: first name, last name and public website.
We will not collect your photos/videos from any of the Social Network Sites unless you submit a photograph/video voluntarily as part of your application to us.
We may also obtain your contact details from publicly available sources, including content that you have made public on Social Network Sites or similar sites for professional purposes to make an initial contact with you for recruitment purposes. We will only do this where you have made your contact details available to the Group to contact you for recruitment purposes. When we contact you in this way, you will be given the option to exercise your right to ask us to cease sending information about careers and opportunities with the Group and/or to have your Personal Data removed from our systems.

Recruitment Agencies
Your Personal Data may also be provided to the Group by recruitment agencies with whom you have registered an interest. Such recruitment agencies provide services to support the Group's recruitment operations under a duty of confidentiality to the Group.

Other sources
While in most cases you will provide your Personal Data yourself, there may be cases when we will request Personal Data about you from third parties for recruitment purposes (e.g. your education establishments, references from previous employers etc.).

HOW WE USE YOUR PERSONAL DATA
Your Personal Data will be used for recruitment purposes, including:
- to identify and contact you;
- to determine your suitability for current or future potential roles with us;
- to provide you with information about job vacancies offered by the Group, upon request; and
- when processing your application and the details of your employment with us.

Where we seek to monitor and implement measures to improve our recruitment initiatives and/or monitor compliance against our policies such as equal opportunities, we would use anonymised and aggregated data (e.g. total number of applicants and country of residence in a given period).
We may use data analytics software for matching your profile with roles with us. When your profile is matched with a role, an email notification regarding that role may be sent to your email address.
We shall not use your Personal Data for any other purposes other than those stated in this Privacy Statement or as otherwise notified to you.

WITH WHOM WE SHARE YOUR PERSONAL DATA
For the purposes stated above, your Personal Data may be disclosed to authorised staff within the Group. The Group may send your Personal Data to a department or office other than the one to which you have sent your application.
In addition, we may disclose your Personal Data to the following third parties in any country:
- agents, advisors or third party service suppliers providing services to support the Group's business operations under a duty of confidentiality to the Group;
- governmental, judicial and other bodies and authorities in compliance with applicable laws and regulations or otherwise;
- advocates/lawyers/solicitors in connection with legal proceedings, to obtain legal advice, or to support the Group's legal rights;
- auditors and investigators in connection with internal and external audits and investigations;
- any third party to whom we may transfer our rights and obligations under any agreement we may have with you in connection with the acquisition, sale or restructuring of any member of the Group;
- any person to whom disclosure is allowed or required by applicable laws and regulations; and
- any court, tribunal, governmental or regulatory authority or law enforcement agency with jurisdiction over any member of the Group.

HOW WE PROTECT YOUR PERSONAL DATA WHEN IT IS TRANSFERRED
As an international organisation, the Group manages its people resources on a global basis and authorised personnel may access your Personal Data in any country in which the Group operates. Therefore, it may be necessary to transfer your details to parts of the Group, its agents, advisors or third party service suppliers, and other third parties authorised to act on our behalf, located in countries that may not offer equivalent data protection or privacy laws to that in countries where you are located. Regardless of where your Personal Data is transferred, we will take all steps reasonably necessary to ensure that your Personal Data is only used according to our instructions and directions and treated securely and in accordance with this Privacy Statement.

UPDATING YOUR PROFILE
If you choose to create a profile on any of our Websites/Social Networks or any other recruitment channel, it is your responsibility to maintain and update the Personal Data provided by you in your profile and the Group may from time to time request, via email that you update your Personal Data to ensure it is accurate. You have the right to access and update your Personal Data at any time by accessing your profile.

HOW LONG DO WE RETAIN YOUR PERSONAL DATA
We will retain your Personal Data for as long as the purpose for which we collected it continues, unless further retention is required to satisfy our legal, regulatory or other obligations or to protect our interests. If you submit a job application and are unsuccessful, the Group may retain your Personal Data for a period of 12 months from our final communication to you in order to match your skills to future job vacancies in the Group, except if there is any objection from you or such other period is required by applicable laws.
The Group may also retain your basic contact information for the purposes of inviting you to join our Talent Network. For these purposes, we may transfer your basic contact information to our Talent Network database. Once you join our Talent Network, you will receive information about the Group, invitations to events and/or receive information regarding job opportunities that may be relevant to your skills. If you choose not to join the Talent Network, we will remove your Personal Data from the Talent Network database, except for minimum details to note that you opted out and so avoid contacting you again about the Talent Network.

HOW WE PROTECT YOUR PERSONAL DATA
The security of your Personal Data is important to us. The Group is required to comply with the Group Information Security Policies and Procedures, which set out security standards including technical and organisational security measures. We require equivalent security measures from our external service providers and other organisations when we share your Personal Data. The Personal Data we collect from you online is stored by us and our service providers on secure servers and protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

MINORS
Our recruitment activities are generally not aimed at minors. If you are a minor in the relevant jurisdiction, you must obtain the consent of your parent or guardian before contacting the Group in relation to recruitment.

COOKIES
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THIRD PARTY WEBSITES
There are links from the Websites to other parts of the Internet that we do not operate or control and our Privacy Statement does not apply when you leave our Websites.

UPDATES TO THIS PRIVACY STATEMENT
The Group reserves the right to amend this Privacy Statement at any time and will place notice of any such amendments on the Websites. Please visit our Websites for the most recent version of this Privacy Statement.

YOUR RIGHTS
If you wish to access your Personal Data, correct/delete any of your Personal Data or have any other questions concerning this Privacy Statement, please contact the Human Capital Department at the contact provided below.
By email: This email address is being protected from spambots. You need JavaScript enabled to view it.
By mail: Attention: Head – Talent Acquisition - Global Talent Acquisition Management, Definition Group 
Address: Definition Group, P.O. Box 35745 - 00100, Nairobi, Kenya
If you registered to receive job alerts or other information and then subsequently you no longer wish to receive such information from us, you have the option at any time to amend your profile choices so as not to receive such job alerts and/or other information from us.