UK Recruiting Privacy Policy

Effective Date: May 26, 2022

1. What Personal Information Do We Collect?

We collect and maintain different types of personal information in respect of those individuals who seek to be employed by us. This may, depending on the jurisdiction and position applied for, include personal information contained in:

• resumes and/or applications;
• information required for travel to and from an interview;
• references and interview notes; and/or
  letters of offer and acceptance of employment;
• and background screening information.

In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, and any other information necessary to verify your identity and evaluate your ability for the role to which you are applying.

As a general rule, Paige collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, such as in the case of a reference or background check, we will obtain your permission before we seek out this information from such sources.

From time to time, we may utilize the services of third parties (including other members of the Paige Family who may be in the United States, and which data transfer is subject to Standard Contractual Clauses) in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us and that their practices align with this privacy policy.

2. How Do We Use Personal Information?

The personal information we collect subject to this policy is used and disclosed for evaluating your eligibility for employment with Paige. Such uses include:

• determining eligibility for initial employment, including the verification of references and qualifications;
• assessing qualifications for a particular job or task;
  complying with applicable labor or employment statutes;
• ensuring the security of company-held information;
  such other purposes as are reasonably required by Paige in connection with your application for employment; 
• and for any additional purposes that we advise you of and for which we have a legal basis.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

3. Monitoring

In the course of conducting our business, we may monitor activities on our systems for security purposes. For example, some of our locations are equipped with surveillance cameras in public areas and our websites are monitored for suspicious activity. Where in use, surveillance cameras and website monitoring are there for the protection of employees and third parties and to protect against theft, vandalism and damage to Paige’s goods and property. Generally, recorded images are routinely destroyed and not shared with third parties unless there is suspicion of a crime, in which case they may be turned over to law enforcement or other authority.

This section is not meant to suggest that all applicants will in fact be monitored or their actions subject to constant surveillance. It is meant to bring to your attention the fact that such monitoring may occur and may result in the collection of personal information.

4. When Do We Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants and other parties (including other members of the Paige Family) who require such information to assist us with evaluating your qualifications for employment, including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you. In some instances, such parties may also provide certain information technology and data processing services to us so that we may communicate with you, coordinate scheduling for interviews, arrange travel or similarly operate our business. We may share personal information with such parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America, and in some cases, other countries. Personal information is transferred by us to another country, including within the Paige Family, if this is required or permitted under the applicable privacy laws and regulations, in particular providing an equivalent level of data protection in the recipient country.

When we share personal information with such parties we typically require that they only use or disclose such personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy.

In addition, personal information may be disclosed or transferred to another party (including to another member of the Paige Family outside of your home jurisdiction) in the event of a change in ownership of, or a grant of a security interest in, all or a part of Paige through, for example, an asset or share sale, or some other form of business combination, merger or joint venture.

Further, your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of Paige’s regular reporting activities to other members of the Paige Family (including outside of your home jurisdiction);
• to protect the rights and interests of Paige where it is not outweighed by the risk of harm to you;
  where the personal information is publicly available;
• or with your consent where such consent is required by law.

We do not sell personal information subject to this privacy policy to third parties.

5. Consent

Applicants submitting personal information for the purposes of pursuing employment are doing so voluntarily, and may withdraw their candidacy at any time. The personal information submitted may need to be retained for a short time (<1 year or as required by law) for official records, but will not be retained beyond that time or for any other purpose.

Paige may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to [email protected].

6. How is Your Personal Information Protected?

Paige endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question, and maintains an ISO 27001 certification. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Despite these safeguards, no method of transmission over the Internet or data storage is fully secure. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

7. How Long is Your Personal Information Retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, Paige endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you

8. Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your application for employment, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

9. Access to Your Personal Information and Deletion of Your Personal Information

You can request access to, and rectification or deletion of personal information that we hold about you.

To make such a request, please contact the office of our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing. In your request, please make clear what specific personal information you would like to have accessed, rectified, or deleted.

When requesting access to, or rectification or deletion of your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, rectify or delete, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access, rectify, or delete the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to, or rectification or deletion of your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

We will not discriminate against you for exercising any of your rights described in this Privacy Policy.

10. Inquiries or Concerns

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner or supervisory authority applicable for your jurisdiction.

11. Privacy Officer

Paige has appointed a privacy officer to oversee compliance with privacy policies. The Privacy Officer can be reached via email at [email protected].