EVOX THERAPEUTICS: RECRUITMENT PRIVACY NOTICE
The purpose of this Recruitment Privacy Notice (“Notice”) is to explain how Evox Therapeutics Limited (also referred to as “Evox”, “we”, “our”, “us”), handles personal data about Evox job applicants in connection with our recruitment activities and to explain the rights that applicants have under data protection law.
Evox is the controller in respect of personal data that it collects, uses and manages in accordance with this Notice.
1. CATEGORIES OF PERSONAL DATA WE COLLECT ABOUT YOU
Over the course of the recruitment process and if you do not opt out, for future recruitment activities of Evox, we collect various types of personal data about you, which may include the following:
• Full name, telephone number, personal email address, gender, home address, availability, employment history and educational history;
• Background information, such as your CV, documentation relating to your right to work, status and details of any immigration visas and/or requirements, and third party references and any cover letter you may provide to us, information relating to current or previous employments;
• Information you provide to us during an interview or that we collect through the recruitment process (e.g., interview notes a details of your willingness to relocate, salary expectations, current salary and salary history, type of employment contract, results of any assessment);
• Reference information including information provided by third parties such as past employers, educational institutions, and references and information related to animal rights activities to ensure a safe working environment at Evox as part of background checks performed by Evox; and
• Details of interests, preferences and opinions relevant to our business and operations.
Additionally, we may collect information relating to your health or whether or not you have a disability, which is classed as ‘special category’ personal data, in order to enable us to verify your right to work, for the purposes of our equal opportunities monitoring and reporting and to make appropriate adjustments for you in the interview process where required to accommodate any disabilities you may have. The above categories of personal data are generally collected directly from you when you submit a job application, including in particular via the careers page on the Evox website (https://careers.evoxtherapeutics.com/), and at other stages during the interview process. We may also receive personal data about you from other sources such as through recruitment agencies and former employers.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose, including to improve our recruitment practices. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be processed in accordance with this Notice.
2. HOW WE USE YOUR PERSONAL DATA
We use personal data about you for a range of standard recruitment-related and business purposes, including:
• To assess your skills, qualifications and suitability for a role, in order to shortlist applicants and to verify references and professional qualifications;
• To communicate with you before, during and after the recruitment process;
• To provide appropriate adjustments during the recruitment process to accommodate any disability or illness you might have;
• To maintain an internal record of our hiring process and the details of unsuccessful applicants, to streamline and improve the efficiency of future hiring processes;
• Other legitimate interests, including our interests in considering candidates for current and future employment opportunities and in managing and improving our recruitment and hiring process, as well as protecting our confidential information and data;
• To ensure the security of our premises, assets, information, employees and other personnel; and
• For legal and compliance purposes, such as compliance with health & safety requirements, as part of any visa application for working in the UK or for providing supporting evidence for any application which may be for other candidates applying for the same role, and other legal or fiscal obligations, or in connection with litigation or an internal investigation or audit and to ensure compliance with our policies regarding, equal opportunity monitoring and reporting obligations, anti-money laundering, bribery and corruption.
We may verify the personal data you provide during the recruitment process and/or collect personal data about you from sources other than you to assist with our ‘Pre-Employment Checks’. This may include checking your qualifications, directorships, financial history (e.g. bankruptcy). If this occurs You will be told in advance which aspects of your personal data will be verified including an explanation of how the Pre-Employment Checks will be carried out.
3. LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
Under UK data protection laws applicable to the processing of your personal data, we are required to have a lawful basis for processing personal data. Our processing of personal data for the purposes described above is based on the legal grounds that it is:
• Necessary to evaluate and potentially enter into a contract of employment with you;
• Necessary to comply with our legal obligations, for example, to check you have the right to work in the UK and as part of our obligations for complying with employment laws; or (as applicable)
• For our legitimate interests, including our interests in considering candidates for current and future employment opportunities and in managing and improving our recruitment and hiring process, unless those interests are overridden by your interests or fundamental rights and freedoms.
• Consent, where we contact you after three years after the end of the first recruitment process, to see if you wish to continue to receive such recruitment information, as set out in section 7.
Our processing of your ‘special category’ personal data is based on the legal grounds that it is:
• Necessary to enable us to exercise our legal rights, and/or to perform our legal obligations as your potential employer (e.g. to ensure your health and safety during the recruitment process);
• Necessary for or in connection with actual or proposed legal action, in order for Evox to obtain legal advice or to establish, exercise or defend its legal rights.
4. SHARING YOUR PERSONAL DATA OUTSIDE EVOX
We may need to share some of the above categories of personal data, with parties outside Evox, such as HR consultants; third party service providers (e.g. service providers of verification/background checking services or companies which host our recruitment data for us); third parties to whom we may choose to sell, transfer or merge part of our business or our assets; and professional advisers. The recipient of the information will be bound by confidentiality obligations.
We may also be required to share some personal data with third parties to comply with law. For the most part, such information will be shared for the purpose of processing your application and conducting such verification and/or background checks as are applicable to your role in the event you are selected.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. INTERNATIONAL TRANSFERS
Some of our service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us using the contact details set out below, if you want further information regarding international data transfers.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. DATA RETENTION
If your application for employment is successful, personal data gathered during the recruitment process will become part of your employment record and will be retained during your employment in accordance with our internal employee data protection notice and retention policies.
If your application for employment is unsuccessful (or you withdraw from the process or decline our offer), and unless you have explicitly opted-out, we will retain your personal data for a reasonable period of time (no longer than three years and six months) beyond the end of the application process for the purpose of considering you for other current and future employment opportunities at Evox unless you provide your consent for us to continue to process your Personal Data in accordance with this policy for the purposes of being considered for future roles at Evox, following which you may withdraw your consent at any time by contacting us. If you no longer want us to contact you regarding other roles, please contact us using the details in the Points of Contact section below. After the three year and six months period, if you do not provide your consent, or at the point that you communicate that you no longer want us to retain your personal data we will, subject to any further retention period that we apply for the purposes of complying with our legal obligations or resolving disputes, securely destroy personal data about you in accordance with applicable laws.
8. YOUR LEGAL RIGHTS
If you are in the EU or UK, you have the right under EU/UK data protection laws to access personal information held about you, subject to certain conditions, and to ask for it to be changed or deleted.
If you would like to access or amend the personal information which we hold about you, or if you would like us to stop using your personal information, please contact us.
Your rights
By law you have the following rights with regard to your personal information:
• Access. You have the right to obtain confirmation as to whether or not your personal information is being processed, and, if it is, request access to that personal information (commonly known as a “data subject access request”). We will need you to prove your identity before we release any personal information to you.
• Correction or deletion. You have the right to ask us to correct or delete any personal information that we hold about you (unless we have the legal right to retain it). You also have the right to ask us to delete your information where you have exercised your right to object to processing (see below).
• Objection. You have the right to object to processing of your information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
• Restriction. You also have the right to restrict us from processing your personal information. You can ask us to temporarily stop processing information about you, for example if you want us to establish that it is accurate or the reason for processing it.
• Data portability. In some circumstances, you have the right to ask us transfer a copy of the personal information we hold about you to someone else.
If you would like to exercise any of the rights mentioned above, please contact us.
• The above rights do not apply to anonymised personal information.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. COMPLAINTS AND POINTS OF CONTACT
If you have any questions about this Notice or are not happy with the way that we have handled your personal data, please contact our Legal Department by post to Evox Therapeutics Limited, Oxford Science Park, Medawar Centre, 2nd Floor East Building, Robert Robinson Avenue, Oxford OX4 4HG, by email to Legal@evoxtherapeutics.com.
If you are still not happy, you have the right to make a make a complaint to your local data protection regulatory authority.
If you are based in the UK, you can contact the Information Commissioner’s Office using the link here: https://ico.org.uk/global/contact-us/. For contact details of the relevant data protection authority in the EU, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_e...
Last updated: April 2024
