CPI CARD GROUP – UK LIMITED
APPLICANT PRIVACY NOTICE
WHAT IS THE PURPOSE OF THIS DOCUMENT?
CPI Card Group – UK Limited (“CPI”) is committed to protecting the privacy and security of your personal information. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). This privacy notice describes how we collect and use personal information about you for the purposes of the recruitment process, in accordance with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”).
DATA PROTECTION PRINCIPLES
Under applicable data protection law, the personal information we hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Maintained only as long as necessary for the purposes we have told you about.
• Stored and handled securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
• The information you have provided to us in your curriculum vitae and covering letter.
• The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, education, employment and compensation history, and qualifications.
• Any information you provide to us during an interview.
• Any other information you provide us during the recruitment and onboarding process
We may also collect, store and use the following "special categories" of more sensitive personal data, which require a higher level of protection:
• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offences.
• Information about credit history.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
• You, the candidate.
• Former employers.
• Recruitment agencies (if you applied through one), from which we collect the following categories of data: curriculum vitae and covering letter.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information to the extent the law allows us to. Most commonly, we will use your personal information to:
• Assess your skills, qualifications and suitability for the position.
• Carry out background and reference checks, where applicable.
• Communicate with you about the recruitment process.
• Keep records related to our hiring processes.
• Comply with a legal obligation.
Once we receive your curriculum vitae, cover letter or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the position. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to contact you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the position, to continue the interview process, or to conclude the process without offering you a position. If we decide to offer you the position, we will then check your references, conduct a criminal record check (subject to the provisions below), and education and credit checks before we make you an offer.
If you fail to provide personal information
If you fail to provide certain information, which is necessary for us to consider your application (such as evidence of qualifications or employment history), we will not be able to process your application successfully. For example, if we require a credit check or references for this position and you fail to provide us with that information, we will not be able to consider your application further.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We may use “special categories” of personal information we collect about you in the following circumstances:
• We will use information about your disability status to consider whether we need to provide certain accommodations during the recruitment process.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
We envisage that we will process information about criminal convictions.
We will only collect information about criminal convictions if we would like to offer you the position. We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history, which makes you unsuitable for the position. In particular:
• The positions within our card manufacturing and personalisation requires a high degree of trust and integrity since it involves dealing with business and consumer data and producing cash equivalent product and so we would like to ask you to seek a basic disclosure of your criminal records history.
We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such information.
AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
We do not anticipate that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
DATA SHARING
We may have to share your personal information with third parties, including third-party service providers and other entities in the CPI group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, we will do so only as allowed by law and you can expect a similar degree of protection in respect of your personal information. For example, we have a Data Processing Agreement with appropriate model contractual clauses in place with our parent company in the United States. You may obtain a copy of such contractual clauses by sending a request to our Data Protection Officer.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application, including our parent company and affiliated entities, background checking companies, HireRight, ICIMS for recruitment and onboarding software.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
DATA RETENTION
How long will you use my information?
We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to offer you employment with us. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will seek your consent to retain your personal information for a fixed period on that basis.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is current and accurate. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
RIGHT TO WITHDRAW CONSENT
When you applied for this position, you provided consent to us processing your personal information for the purposes of the recruitment process. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Talent Management Manager and/or DPO. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
DATA PROTECTION OFFICER
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at skilgore@cpicardgroup.com, CPI Card Group, 10026 W. San Juan Way – Suite 200, Littleton, CO 80127, (001) 303-345-2423. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact Sarah Kilgore, Chief Legal and Compliance Officer.
