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LERC Recruitment GDPR Privacy Policy

LOW EMISSIONS RESOURCES CORPORATION
RECRUITMENT PRIVACY POLICY

Low Emissions Resources Corporation, Low Emissions Resources Global, and its subsidiaries, affiliates and related entities (collectively, “LERC,” “we” and “our”) are committed to protecting and respecting your privacy.

This statement applies to all individuals outside of LERC with whom we interact during our recruitment process (collectively, “you”).

This Recruitment Privacy Notice (together with LERC’s Privacy Policy, Privacy Notice and any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to LERC, will be processed by LERC in connection with our recruitment process. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the General Data Protection Regulation (the “GDPR”) the “Data Controller” is Low Emissions Resources Corporation. As a Data Controller, Low Emissions Resources Corporation determines the purposes and means of the processing of your personal data.

We use an online application provided by Workable Software Limited (together with its subsidiaries, affiliates and related entities, “Workable”), to assist with our recruitment process. We use Workable to process personal information as a “Data Processor” on our behalf, however, Workable is only entitled to process your personal data in accordance with our instructions. As a Data Processor, Workable processes your personal data on behalf of the Data Controller, which in our case is Low Emissions Resources Corporation.

Where you apply for a job opening posted by LERC, these Recruitment Privacy Notice provisions will apply to our processing of your personal information, in addition to our other Privacy Notice and Privacy Policy, which we will provide to you upon request.

Where you apply for a job opening via the application function on a job site or similar online service provider (each, a “Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from LERC in respect of the progress of your application. Any use by the Partner of your data will be in accordance with that Partner’s privacy policy, and not LERC’s.

I.    Personal Information

We use the term “personal data” to mean any information that that relates to an identifiable individual. For LERC to administer the recruitment process, personal data is required to be provided by you, and failure to provide or allow LERC to process such personal data may affect our ability to accomplish the purpose stated in this Recruitment Privacy Policy.

II.    Personal Information We Collect from You

We collect and process some or all of the following types of personal data and information from you:

  1. Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
  2. In particular, we process personal details such as name, email address, address, date of birth, qualifications, experience, information relating to your employment history, skills and experience that you provide to LERC.
  3. If you contact LERC, we may keep a record of that correspondence.
  4. A record of your progress through any hiring process that we may conduct.
  5. Details of your visits to Workable’s website including, but not limited to, traffic data, location data, weblogs and other communication data, the website that referred you to Workable’s website and the resources that you access.
III.    Personal Information We Collect from Other Sources

Workable provides LERC with the facility to link the data you provide to LERC with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Workable’s technology allows LERC to search various databases, some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill our job openings. Where we find you in this way, we will obtain your personal data from these sources.

We may also receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

IV.    Lawful Basis for Processing Your Personal Information

We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are the recruitment of staff for our business.

Where you apply for a job opening through the Indeed Apply functionality, we rely on your consent, which is freely given by you during the application process, to disclose your personal data to Indeed on the basis described below in Section VII.

V.    Purposes of Processing

We use the personal information we receive from you in the following ways:

  1. To consider your application in respect of a role for which you have applied;
  2. To consider your application in respect of other roles;
  3. To communicate with you in respect of the recruitment process;
  4. To enhance any information that we receive from you with information obtained from Workable, Partners and/or other third party data providers;
  5. To find appropriate candidates to fill our job openings; and
  6. To help our service providers (such as Workable and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.
VI.    Automated Decision Making/Profiling

We may use Workable’s technology to select appropriate candidates for LERC to consider based on criteria expressly identified by LERC, or typical criteria related to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by LERC’s staff.

VII.  Disclosure of Your Information

As set out above, we pass your information to our third-party service providers, including Workable, who use it only in accordance with our instructions and as otherwise required by law.

Where you have applied for a job opening through the Indeed Apply functionality, and where you have consented to this disclosure, we will disclose to Indeed certain personal data that we hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s privacy notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

Where you have applied to a job opening through another Partner and/or service provider, we may disclose data similar to the Disposition Data defined above to such Partner and/or service provider. The Partner and/or service provider shall be the Data Controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by us.

VII.    Security of Your Personal Information

We take appropriate measures to ensure that all personal data is kept secure, including security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business and are on a need-to-know basis. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to manage any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

VIII.    Where We Store Your Personal Data

Your personal data is stored in our own secure company server, which allows only SSL VPN access and is protected by Cisco ASA 5506-X firewalls. We may also store your personal data in Dropbox, which is certified GDPR compliant as well as certified compliant with the most widely- accepted global security and privacy standards and regulations, such as ISO 27001/2, ISO27018/17 and SOC 2.

The data that we collect from you and process using Workable’s services may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA”). It may also be processed by staff operating outside the EEA who work for LERC. By submitting your personal data, you agree to this transfer, storing or processing.

In particular, your data may be accessible to (a) Workable’s staff in the United States of America (“USA”), or (b) may be stored by Workable’s hosting service provider on servers in the USA as well as in the European Union (“EU”). The USA does not have the same data protection laws as the United Kingdom (“UK”) and EEA. A data processor agreement has been signed between Workable and its overseas group companies, as well as between Workable and each of its data processors (each, a “Data Processor Agreement”). These Data Processor Agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information please contact LERC at the email provided in “Contact” below. We will not otherwise transfer your personal data outside of the UK or EEA, or to any organization (or subordinate bodies thereof) governed by public international law or which is established under any agreement between two or more countries.

IX.  How Long We Keep Your Personal Data

We will hold all the personal data and information that we receive for twenty-four (24) months.

Before such time, your personal information may also be deleted on one of the following occurrences:

  1. Deletion of your personal information by you (or by another person engaged by the you); or
  2. Receipt of a written request to delete your personal information by you (or another person engaged by the you) to us.
X.    Your Rights

Under the GDPR, you have a number of important rights in relation to your personal data, which include:

  1. Access to your personal data and to certain other supplementary information that this Recruitment Privacy Notice is already designed to address;
  2. Require LERC to correct any mistakes in your information which we hold;
  3. Require the erasure of personal data concerning you in certain situations;
  4. Receive the personal data concerning you which you have provided to LERC, in a structured, commonly used and machine-readable format and have the right to transmit such data to a third party in certain situations;
  5. Object at any time to processing of personal data concerning you for direct marketing;
  6. Object to  decisions  being  taken  by  automated  means  that  produce  legal  effects concerning you or similarly significantly affect you;
  7. Object in certain other situations to our continued processing of your personal data;
  8. Otherwise restrict our processing of your personal data in certain circumstances;
  9. Claim compensation for damages caused by our breach of any data protection laws; and
  10. Lodge a complaint with a data protection authority for alleged infringements of these rights.

For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (the “ICO”) on individuals’ rights under the GDPR, located on the ICO’s website.

If you would like to exercise any of these rights, please:

  1. Contact LERC using our “Contact” details below;
  2. Allow LERC to have enough information to identify you;
  3. Allow LERC to have proof of your identity and address; and
  4. Allow LERC to know the information to which your request relates.
XII. How to Complain

We hope that we can resolve any query or concern you may raise regarding LERC’s use of your information.

As stated above, the GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the ICO who may be contacted at https://ico.org.uk/concerns/ or by telephone at 0303 123 1113 if you are inside the UK, or +44 1625 545 700 if you are outside the UK.

XII. Contact

All questions, comments and requests regarding this Recruitment Privacy Notice should be addressed to HR@LERCorp.com.