This Policy applies to all Personal Information related to job applicants that is Processed by the Company, whether in electronic format or in a structured filing system.
Terms used in this Policy
- “Candidate” - Any applicant for a position at the Company as a temporary, full-time or part-time employee, intern, contractor or contingent worker.
- “Personal Information” - Any information relating to you.
- “Processor” - An entity that processes Personal Information on behalf of the Company.
- “Processing” (and any variant of such term) – Any action taken on Candidate Personal Information such as collecting, recording, storing, organizing, altering, using, disclosing, transmitting or deleting, including if performed by automated means.
Roller Networks Pty Ltd is the primary Controller of the Personal Information for the purpose of this Policy. Our postal address is:
PO Box 562
South Melbourne, 3205
We can also be contacted through the following email address: email@example.com.
How we collect data and why
We will collect and Process Candidate Personal Information for the purpose of administering employment applications and for various necessary recruitment purposes prior to making a hiring decision and, where relevant, entering into an employment agreement.
Candidate Personal Information includes, for example, name, contact details, physical address, date of birth, photograph (if you proactively provide it with you CV), details of your qualifications, employment history, Information included in your CV or cover letter, job preferences, current and historic salary details (if permitted under law) together with salary expectations, details of your current benefit entitlements.
Personal Information may also include names and contact details for references. Please note that it is your responsibility to obtain consent from your references prior to providing us personal information about them.
You are not under any legal obligation to provide us Personal Information. However, we do need it to consider your job application.
The Company may also collect Personal Information about Candidates from other third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks where necessary or required by law.
The Personal Information about Candidates originates from you, the Candidate, via hard copy and web-based application forms, and also from recruiters and recruitment agencies and through individual referrals.
Should your application be successful, relevant data will be transferred to our HR information system.
Purposes of Processing Personal Information
Your Personal Information will be Processed for the purposes and on the basis detailed below. We may Process the Personal Information for additional purposes, provided that policy is given to you, and provided that we receive your consent if so required under the law.
Example of data categories
Legal Basis under UK and EU law
Recruitment – Reviewing your candidacy for the open position you applied for
Interviews, assessment tests and questionnaires, references from other parties
Contact details, birthdate, education, CV, referrals, employment history, salaries (if permitted under law) , work permits, social, identification documents, email correspondence with you.
Defending or asserting legal claims relating to your candidacy
If you or a third party asserts a legal claim against us about how we handled your candidacy
Retaining your candidacy for future positions beyond the ones you applied for
If we later have a job opening for a similar position that may be relevant to you
Sharing Candidate Personal Information
We will share your Candidate Personal Information within our internal HR team. We may also share some of Candidate Personal Information with Processors engaged by us to provide services we require to use Candidate Personal Information for permitted purposes. Such Processors operate under our instructions. We aim to ensure that any Processor we use takes adequate measures to protect your Candidate Personal Information, by signing a data processing agreement with it, though we cannot guarantee the practices of these third parties are maintained and followed.
We do not sell your Candidate Personal Information to third parties.
Because we operate our business as a corporate group of companies, we may also share your Candidate Personal Information with companies in our corporate group for the same purposes set out above. These entities are those controlled by, under the control of, or under common control with Roller Networks Pty Ltd. These are primarily the following entities:
|Roller Networks Australia Pty Ltd (incorporated in Australia)
Where required by law, we will also disclose your Candidate Personal Information to a governmental authority, in response to legal process or when we believe in good faith that the law requires it. The legal basis for this is a legal obligation we are subject to and our legitimate business interests in complying with binding requests of governmental authorities.
International data transfers
If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.
|Roller Networks USA Inc. (incorporated in Delaware)
Roller Networks Limited (incorporated in England)
Retention and security
Retention. Personal Information of unsuccessful Candidates to which the GDPR applies will be deleted within 24 months of the decision, unless we decide to retain the information for an additional period of 18 months for the purpose of considering you for other potential job opening.
We will retain the Personal Information of unsuccessful Candidates in the U.S. indefinitely.
Safeguards. We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of Candidate Personal Information. We also request our affiliates to implement such measures in order to secure the information we provide them. However, although efforts are made to secure Candidate Personal Information, we cannot guarantee its absolute protection.
EU and UK Rights
If you are in the EU or the UK, you have the following rights under the GDPR:
Right to Access and receive a copy of your Candidate Personal Information that we Process.
Right to Rectify inaccurate Candidate Personal Information we have concerning you and to have incomplete Personal Information completed.
Right to Data Portability that is, to receive the Candidate Personal Information that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another person or entity. Where technically feasible, you have the right to have your Candidate Personal Information transmitted directly from us to the person or entity you designate.
Right to Object to our Processing of your Candidate Personal Information on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to Process such Candidate Personal Information for the establishment, exercise or defense of legal claims.
Right to Restrict us from Processing your Candidate Personal Information (except for storing it): (a) if you contest the accuracy of the Candidate Personal Information (in which case the restriction applies only for a period enabling us to determine the accuracy of the Candidate Personal Information); (b) if the Processing is unlawful and you prefer to restrict the Processing of the Candidate Personal Information rather than requiring the deletion of such data by us; (c) if we no longer need the Candidate Personal Information for the purposes outlined in this Policy, but you require the Candidate Personal Information to establish, exercise or defend legal claims; or (d) if you object to our Processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).
Right to be Forgotten. Under certain circumstances, such as when our Processing of your Candidate Personal Information is based on your consent, you have the right to ask us to erase your Candidate Personal Information. However, notwithstanding such request, we may still process your Candidate Personal Information if it is necessary to comply with our legal obligations, or for the establishment, exercise or defense of legal claims.
If you wish to exercise any of these rights, contact us through the channels listed below.
When you contact us, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, particularly in the Member State of your residence, place of work or place of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
If you are in the UK, you can lodge a complaint to Information Commissioner’s Office (ICO) pursuant to the instructions provided here.
Additional information for Individuals residing in California
If you are an individual residing in California, we provide you the following information pursuant to the California Consumer Privacy Act (CCPA):
Categories of Personal Information (Under the CCPA)
Specific Types of Personal Information Collected
Business Purposes For Which the Information Is Used (Under the CCPA)
Specific Details on the Business Purpose
Identifiers of the Candidate
Your name, residential address
Other information that identifies, relates to, describes, or is capable of being associated with, the Candidate
Your telephone number, demographic information, employment status, title, family status, status in the U.S. and information on your right to work in the U.S.
Professional or employment-related information
Your professional education and training, employment history, references
Inferences drawn from any of the information identified above to create a profile about the Candidate
Assessment of characteristics, skills, abilities and aptitudes
We do not recruit or employ individuals under the age of 18. We do not knowingly collect Personal Information about individuals under that age, other than Personal Information about your minor underaged children that we may process for purposes like HR administration, tax reporting provision of insurance, etc. We do not sell Personal Information about minors.
We reserve the right to ask for reasonable evidence to verify your identity before we handle you data subject request. Where we are not able to provide you the information that you have asked for, we will explain the reason for this.