Introduction
This Candidate Privacy Notice (“Notice”) applies to Moveads LTD , with registered office Suite 23050 8 Shepherd Market, Mayfair, London, United Kingdom, W1J 7JY and all clients who contractually ordered recruitment services and information about which will be disclosed to candidate (“Spalah” “we,” “us,” or “our”) and outlines how Spalah collects, uses, stores, and shares personal data related to candidates and other individuals who apply for open roles with us; who we contact regarding, or who express interest in, employment with Spalah; who attend recruitment events; or who participate in interviews or assessments with us (“Candidate(s)”). This Notice also describes the rights that Candidates may exercise regarding the personal data we process about them. For the purposes of this Notice, “personal data” refers to any information that identifies, relates to, or could reasonably be used, directly or indirectly, to identify an individual.
If you are extended an offer and accept a role at Spalah, the personal data collected during the recruitment process will be incorporated into your employee file and will then be governed by our other applicable privacy policies.
Our privacy policy is available here.
1. Candidate Personal Data We Collect and Share
What Personal Data Do We Collect from Candidates?
We collect a range of personal data to facilitate our recruitment process, including:
Identifiers: Name, contact details (postal address, phone number, email), and other similar information.
Application Information: Details related to your job application, such as assessments completed during the application process and information gathered through our interactions.
Work Authorization Information: Data needed to confirm your eligibility to work with Spalah, which may be required by local law, such as immigration status, citizenship, visa information, or proof of vaccination.
Public Information: Information available on social media profiles, where allowed by law.
Professional and Employment History: This includes certifications, résumé, curriculum vitae, cover letter, training courses, publications, academic transcripts, work history, qualifications, performance records, references, and background information verified by academic institutions or certification providers. We may also receive information from recruiting agencies.
Additional Information: Any other personal data you voluntarily provide, such as compensation history.
Sensitive Personal Data: In some cases, we may collect optional sensitive data, such as government identifiers, race or ethnic background, gender identity, sexual orientation, medical conditions, disability status, visa and immigration information, and proof of vaccination. Such data shall be collected only optional and if necessary for the interests of candidate.
To Whom Do We Share Candidate Data?
We may share candidate personal data with the following:
Service Providers: Including providers for data storage and recruitment platforms.
Government Entities: Law enforcement and other government bodies, as necessary for compliance, security, and legal purposes.
Corporate Transactions: In the event of a corporate transaction, such as a sale, acquisition, or merger involving some or all of our assets.
Professional Advisors: Such as legal, accounting, and audit professionals.
Affiliates and Subsidiaries: Including our parent companies, affiliates, and subsidiaries, as well as any businesses acquired by Spalah in the future.
With Your Consent: Any other disclosures that you have explicitly consented to.
If we request any additional information not listed above, we will inform you at the time of collection about the purpose of that data and how it will be processed. Additionally, where legally permissible, we may de-identify, anonymize, or aggregate personal data to share with third parties for any lawful purpose.
We may also share your personal data in response to lawful requests from law enforcement or other governmental bodies, including requests related to national security requirements.
2. Your Rights as a Candidate
As a candidate, you have several rights regarding your personal data:
Right to Access: Request a copy of your data and information about its processing.
Right to Rectification: Correct inaccurate or incomplete personal data.
Right to Erasure: Request deletion of personal data under specific conditions.
Right to Restrict Processing: Request limitations on processing your data under certain circumstances.
Right to Data Portability: Receive your data in a structured format for your own use or transfer.
Right to Object: Object to data processing based on legitimate interests.
Right to Withdraw Consent: Withdraw consent for processing sensitive data at any time without affecting the lawfulness of prior processing.
To exercise your rights, please contact legal@spalah.tech.
3. How We Process Candidate Personal Data
We may process your personal data for the following purposes:
Purpose of Processing | Lawful Basis |
Recruitment and Hiring: To assess your qualifications for employment and support the hiring decision-making process. For example, we may process your data when evaluating your candidacy and communicating with you about the hiring process. When legally permissible, we may contact you regarding roles at Spalah that align with your skills and experience. Employment Recommendations: To obtain recommendations and verify information provided during the recruitment process, we may contact your previous employers or references you have provided. Enhancing the Recruitment Process: To analyze and improve our recruitment practices, including promoting diversity, equity, and inclusion, where permitted by applicable law. Referrals: To facilitate referrals, if you were recommended for a role with Spalah by an employee using our referral system. This may include using the contact information provided to reach out to you as permissible by law. | Legitimate interests |
Accommodations: To provide any necessary accommodations during the recruitment process based on physical or mental health requirements you disclose. | Legal obligations |
Equal Opportunity and Legal Compliance: To monitor for equal opportunity compliance, adhere to anti-discrimination laws, and meet governmental reporting requirements. | Consent; Legal obligations |
Legal Purposes: To establish, exercise, or defend legal claims. | Legal claims; Legal obligations |
Safety and Security: To protect the safety, security, and integrity of our systems and technology assets, ensure the rights and safety of those who interact with us, and detect, prevent, or address security incidents or other unauthorized, deceptive, or illegal activities. This may involve collecting and processing sensitive data, such as health information, when necessary for public health reasons or as required by law. | Legitimate interests; Public interest; Legal claims; Vital interests; Legal obligations |
Contractual Requirements: To perform a contract to which you are a party or take steps at your request before entering a contract, such as preparing for an employment agreement with you. | Contract |
Spalah will honor data subject rights to the extent required by law. You may have the right to access, correct, update, and, in some cases, request deletion of your personal data (subject to exceptions).
When you apply for a position at Spalah through our website, you will be redirected to the recruitment platform BambooHR. Spalah remains the data controller for your personal data, while BambooHR acts as our data processor, processing your information solely on our behalf and in accordance with our instructions.
The personal data you provide through BambooHR is processed in line with this Candidate Privacy Notice as well as BambooHR’s own privacy policy, available here (https://www.bamboohr.com/legal/privacy-policy).
4. Sources of Candidate Personal Data
We may gather candidate personal data from the following sources:
Directly from You: Personal data you provide directly, such as through job applications, résumés, and during interviews or assessments.
From Other Individuals: Information collected from individuals you list as references, such as former or current employers, colleagues, or friends. We may also collect personal data if someone refers you for a position at Spalah, as permitted.
Publicly Available Information: Data you have shared publicly, such as content on personal websites or public social media profiles, where permitted by law.
From Third Parties: Information from external sources, including professional or sanctions registries, background information verified by academic institutions, training or certification providers, and recruiting or executive search agencies.
We may combine data from these various sources and use or disclose it in line with the purposes outlined in this Notice.
5. Retention of Candidate Personal Data
Your personal data will be stored in compliance with applicable laws and retained as long as necessary to fulfill the purposes outlined in this Notice, or as otherwise required by law. If your job application is successful, your personal data will be managed in line with other relevant policies. If your application is not successful, we will retain your personal data for the duration of the application process, plus a reasonable period afterward to document our hiring decision and allow for the establishment, exercise, or defense of any legal claims. Where allowed, we may also retain your personal data for a reasonable time to consider you for future suitable roles at Spalah.
If you prefer to opt out of our policy of retaining your information for future opportunities, please email legal@spalah.tech.
6. International Data Transfers
Your personal data may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your jurisdiction. When we transfer personal data internationally, we ensure it is protected in accordance with this Notice and applicable legal requirements, including GDPR, using standard contractual clauses or other legally recognized safeguards.
If required by law, we will obtain your consent before transferring your personal data to certain jurisdictions. For transfers outside the European Economic Area (EEA) or other regions with comprehensive data protection laws, we have implemented appropriate safeguards to ensure your personal data remains protected, including by entering into data transfer agreements in accordance with applicable laws.
7. Contact Information
If you have questions or complaints regarding this Notice, please contact us by email at legal@spalah.tech.
8. Modifications to This Notice
We may update this Notice periodically to reflect changes in legal, regulatory, or operational requirements, our practices, or other relevant factors. Please review this Notice periodically for any updates. Where required by applicable law, we will notify you of significant changes by posting an alert on this page before the changes take effect (and updating the "Last Updated" date at the top of this Notice) or by other appropriate means.