Global Shares Recruitment Privacy Notice

Last Updated: January 2022

When we refer to “Personal Data” in this Privacy Notice we mean any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

OUR RECRUITMENT PRIVACY NOTICE

Under the General Data Protection Regulation (the “GDPR”), we are required to explain to you why we are asking for information about you, how we intend to use the information you provide to us and whether we will share this information with anyone else.

We must also explain your rights under the GDPR and related data protection laws in relation to our processing of your Personal Data. Our general Privacy Notice is available on our website www.globalshares.com

This recruitment Privacy Notice sets out specific information relating to applicants for permanent and temporary positions in our company (“Applicants”).

Global Shares has split our Privacy Notice into four separate notices as follows:

  • The General Business Privacy Notice describes how we process personal data of business contacts and website visitors
  • The Participant Privacy Notice  describes how we process data of registered users who have share accounts with Global Shares. .
  • Our Recruitment Privacy Notice (This notice) informs job applicants how we will process their data through our recruitment process.
  • Our Employee Privacy Notice is made available to all employees via our HRIS platform.

We treat the protection of your personal data seriously and when we collect and process your Personal Data, we will do so in accordance with the GDPR and relevant local data protection laws (the “Data Protection Laws”).

ABOUT US

We are
Global Shares and affiliate companies
You can find us at
West Cork Technology Park, Clonakilty, Cork, Ireland
Email
Telephone
+353 (076) 888 7662
Our website is
www.globalshares.com

References to “We”, “Us” the “Company” and “Global Shares” shall apply to the company in the group that is processing your Personal Data.  

We are a company that:

  • Designs and develops enterprise software;
  • Provides equity compensation management solutions for corporate clients who use share plans to engage, align and reward their employees through share ownership and profit sharing;
  • Is authorised by MFSA, FINRA and SEC to provide share dealing services;
  • Is a trust service provider.

This Recruitment Privacy Notice applies to the following companies in the Global Shares group of companies:

Company Name
Company Address
Website
Global Shares Headquarters
West Cork Technology Park, Clonakilty, Cork Ireland
www.globalshares.com
Global Shares Execution Services Limited
171 Old Bakery Street, Valletta, VLT1455, Malta
www.globalshares.com
Global Shares UK Limited
1 Poultry, London, EC2R 8EJ, United Kingdom
www.globalshares.com
Global Shares Inc
1000 North King Street, Wilmington, New Castle County, Delaware 19801, USA
www.globalshares.com
Global Shares Hong Kong Limited
Suite 406-409, 4th Floor, Three Pacific Place, 1 Queen’s Road East, Hong Kong.
www.globalshares.com
Global Shares Portual, Unipessoal LDA
Avenida Defensores de Chaves, No 45, 5gth Floor, 1000-112 Lisbon, Portugal
www.globalshares.com
Global Shares Beijing Limited
Beijing Administration for Industry and Commerce Chaoyang Branch
www.globalshares.com
Global Shares Japan KK
Level 1 Yusen Building 2-3-2, Marunouchi, Chiyoda-ku, Tokyo 100-0055, Japan
www.globalshares.com
Global Shares Saudi Arabia Limited
4124 Prince Mohammed Ibn Salman Ibn Abdulaziz Rd – AlRabie Dist. Unit No 86 Riyadh 13316 – 6664 Kingdom of Saudi Arabia
www.globalshares.com

CONTACT DETAILS

If you have any questions about this Privacy Notice or the way in which your Personal Data is being used by us, please contact our Data Protection Officer:       

Email:                                    [email protected]

WHO THIS PRIVACY NOTICE APPLIES TO

This Recruitment Privacy Notice describes how we process Personal Data in order to recruit prospective employees for permanent and temporary open positions in our company.  It includes detailed information about the types of Personal Data that we process, and how we use, manage and protect that Personal Data.

LAWFULNESS OF PROCESSING

We process all Personal Data lawfully and in accordance with the requirements of the Data Protection Laws. The GDPR sets out the legal grounds for processing Personal Data.

When Global Shares processes Personal Data about Applicants, any one of the following legal grounds will generally apply.  Further detail about the lawful basis for our processing activities is included in the relevant sections of this Privacy Notice.

CONTRACT

We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering that contract. When you apply for a job some of our processing activities will be carried out in order to take steps necessary to enter into a contract of employment with you.

CONSENT

For certain processing activities we may rely on your consent. Where we are unable to collect consent for a particular processing activity, we will only process the Personal Data if we have another lawful basis for doing so.

You can withdraw consent provided by you at any time by contacting us at [email protected]

LEGITIMATE INTEREST

At times we will need to process your Personal Data to pursue our legitimate interests, for example for administrative purposes, to provide information to you, to operate, evaluate, maintain, develop, and improve our websites and recruitment portals or to maintain their security and protect intellectual property rights. 

We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweighs our legitimate interests.

You may object to any processing we undertake on this basis. If you do not want us to process your Personal Data on the basis of our legitimate interests, contact us at [email protected] and we will review our processing activities.

LEGAL OBLIGATION

If we have a legal obligation to process Personal Data, we will process Personal Data on this legal ground.

SOURCES OF APPLICANT DATA

We receive Personal Data about Applicants from a variety of sources. Usually, an Applicant provides us with certain information directly, for example, when the Applicants sends us their CV, applies directly for a position advertised on the Global Shares website, or interacts with our communications (e.g., websites and advertisements).

We may also receive Personal Data about an Applicant when:

  • the Applicant applies to a position advertised on a third-party job’s website;
  • Employee referral;
  • the Applicant may be sourced from publicly accessible platforms such as LinkedIn;
  • the Applicants may be sourced from third party CV providers such as jobs websites that provide CV search facilities and where users have made their CV data available to registered customers of these sites;
  • the Applicant’s nominated referees or other individuals may provide us with Personal Data relating to the Applicants; and
  • carrying out background verification, including fitness and probity checks for Applicants to senior roles.

CATEGORIES OF APPLICANTS PERSONAL DATA

The table below sets out the general categories of Personal Data that we collect in relation to Job  Applicants.

Personal Data Category
Description
Contact Data
may include a person’s email address, phone number, postal address, other communication details (e.g. Skype)
Identification Data
may include a person’s name, date of birth, driver’s license, national tax identification number and passport information
Professional Data
may include profession, company, department, employment history, skills/ experience, membership of professional bodies
Education Data
may include degrees, certificates and diplomas awarded, languages, educational history, qualifications
CV Data
May include Contact Data, Identification Data, Professional Data, Education Data, Application Data, Financial Data, Health Data
Application Data
includes Personal Data provided as part of an application for a permanent or contract position. may include Contact Data, Identification Data, Professional Data, Education Data and information about achievements and hobbies
Financial Data
includes payment and bank details, tax information, social security and salary expectations
Test Data
includes test answers and results for any job application
Media Data
includes video data and recordings from any interview with the Applicants including, Contact Data, Professional Data, Education Data, Health Data, Application Data and Communications Data.
Legal Data
includes criminal record and credit checks undertaken where required as part of the application process. This applies to US Hires where there are FINRA requirements to be met.
Position Data
includes information on salary/rate of pay, working hours and job description
Emergency Contact Data
may include the name and contact details provided by an Applicants in case of an emergency.
Communications Data
may include Personal Data included in communications with us over email, text, phone or letter.
Marketing Data
may include your Contact Data and any preferences in receiving marketing from us and your communication preferences.
Web Data
may include information provided on any forms on our website and, to the extent that it includes Personal Data, information on the type of device you are using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.

OUR PROCESSING ACTIVITIES

We can only collect your Personal Data if we have a lawful basis for doing so.

We have set out in the table below, the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing.

Purpose/Activity
Type of Personal Data
Lawful basis for processing
Applicants Sourcing
• to advertise roles on the Global Shares website and external job boards • to create a record/file for the Applicant on our system and to associate all notes and tracking throughout the interview, and onboarding process • to keep up to date information about Applicants in relation to their requirements, in order to assess their suitability for current or future vacancies • to maintain our shared recruitment drive • screening and identification of Applicants for available positions • to communicate with Applicants about positions that might be of interest to them • to receive and review Applicants applications • to understand current and expected salary, notice period and availability • to respond to applications through our employee referral scheme
CV Data Communications Data Marketing Data
Consent Legitimate interest of Global Shares to effectively manage sourcing and recruitment and communicate with Applicants effectively.
Job Applications
• responding to Applicants queries • receiving and reviewing applications received from Applicants directly • communications with Applicants re application • setting up interviews with the Applicant
CV Data Communications Data
Consent Legitimate interest of Global Shares to effectively manage sourcing and recruitment and communicate with Applicants effectively.
Job Interview
• to arrange and undertake interview • recording notes of Interview and creating score cards • to communicate with the Applicants following interview
CV Data Communications Data Media Data
Consent Legitimate interest of Global Shares to effectively manage sourcing and recruitment and communicate with Applicants effectively.
Applicants Screening
• to identify if the Applicant is fit to work • to assess the Applicant working capacity for the role • to send the Applicant tests to complete • to arrange for references • to determine fitness & probity • to verify the Applicant employment and educational history
CV Data Health Data Test Data Identification data Contact data Finance & Tax data Special category data Employee role data Biometric data Physical characteristics data
Contract Legal obligation
Applicants Finance Activities
• to ensure salary expectations are met • to remunerate Applicant for interview / travel expenses
Contact Data Position Data Financial Data
Contract Legitimate interest of Global Shares to effectively manage sourcing and recruitment and communicate with Applicants effectively.
Applicants IT Activities
• back-up and storage of Applicant data • to make improvements and efficiencies in the recruitment process
Contact Data Identification Data Professional Data Education Data Communications Data Marketing Data
Legitimate interest of Global Shares to effectively manage sourcing and recruitment and communicate with Applicants effectively.
Website Delivery
• to respond to web forms completed by applicants; • to administer the website; • for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes • to ensure the safety and security of our website and our services.
Contact Data Web Data
Legitimate Interest of Global Shares to manage the website and ensure website security
Marketing activities
• to respond to any requests from Applicants • to send newsletters and other information that may be of interest • to participate in recruitment conferences, seminars, events • to personalise marketing information • to segment and distribute targeted marketing
Marketing Data Contact Data Web Data
Consent Legitimate Interest of Global Shares to promote our company to attract prospective employees

RETENTION OF APPLICANTS PERSONAL DATA

We only keep your Personal Data as long as it is necessary for the purposes of processing it or to comply with legal or regulatory requirements.

Our retention policy is as follows:

Purpose of Processing
Retention Period
Job Applications
Duration of campaign +18 months
Applicant Interview
Duration of campaign +18 months
Applicant Expense Reimbursement
Duration of campaign +7 years

In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate interests.  We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.  We may also delete Personal Data earlier than the specified Retention Period where the Personal Data is no longer required for the purpose.

DISCLOSURE OF PERSONAL DATA

Personal Data is shared in certain circumstances as follows:

  • to business partners and sub-contractors for the performance of any contract relating to our recruitment activities including email, chat, ticketing, ATS, hosting service providers;
  • for the purposes of third-party screening and verification, including doctors or testing companies (for example, criminal record checks / pre-employment screening services and assessments)
  • to other companies in the Global Shares group of companies including the affiliated companies documented in this Privacy Notice for the purposes of administration.
  • to any party acquiring an interest in the Global Shares company
  • to tax, audit or other authorities, if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation or in order to enforce or apply any contract that we have;
  • to official authorities to protect our rights, property, or safety, or those of other persons (including you);
  • to providers of services to Global Shares including IT consultants and hosting companies, marketing, legal and finance;
  • to analytics and search engine providers that assist us in the improvement and optimisation of our website. This consists of information relating to the web pages visited on the website and tracking codes from service providers like LinkedIn and Google
  • to Global Shares’ insurance brokers and providers where required for administering claims;
  • to our email distribution partner and service providers in the case of newsletters and other marketing campaigns.

SECURITY

We will take all steps reasonably necessary to ensure that all Personal Data is treated securely in accordance with this Privacy Notice and the Data Protection Laws.  In particular, we have put in place appropriate technical and organisational procedures to safeguard and secure the Personal Data we process.

We monitor for and do everything we can to prevent security breaches of the Personal Data that we process.  Once we have received your Personal Data, we will use strict procedures and security features for the purpose of preventing unauthorised access and ensuring that only those who need to have access to your Personal Data can access it.

We also use secure connections to protect Personal Data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential.  Please do not share your password with anyone.

If you think that there has been any loss or unauthorised access to Personal Data of any individual, please let us know immediately.

TRANSFERS OUTSIDE THE EEA (EU APPLICANTS ONLY)

In certain circumstances your Personal Data may be transferred outside the EEA. We ensure that any transfer of Personal Data outside the EEA is undertaken using legally compliant transfer mechanisms and in accordance with the GDPR.

If we transfer Personal Data outside of the EEA, we generally rely on the Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU Commission. We may also rely on some of the other legally compliant transfer mechanisms provided under the GDPR.

USE OF THIRD-PARTY WEBSITES

External recruitment websites that you may access via a link on the Global Shares website or you may use to apply for a position with Global Shares are outside our control and are not covered by this Privacy Notice. If you use external recruitment websites, the operators of these websites may collect Personal Data from you, which will be used by them in accordance with their own Privacy Notices, which may differ from ours. Please check the Privacy Notices on those websites before you submit any Personal Data to them. 

YOUR RIGHTS

You have various rights relating to how your Personal Data is used.

Right of access to the Personal Data we hold on you

You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to everything we have recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.

We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.

We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others.

Right of rectification of Personal Data

You should let us know if there is something inaccurate in your Personal Data.

We may not always be able to change or remove that Personal Data, but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.  

Right of erasure of Personal Data (right to be forgotten)

In some circumstances you can ask for your Personal Data to be deleted, for example, where: 

  • your Personal Data is no longer needed for the reason that it was collected in the first place
  • you have removed your consent for us to use your Personal Data (where there is no other lawful basis for us to use it)
  • there is no lawful basis for the use of your Personal Data
  • deleting the Personal Data is a legal requirement

Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.

Please note that we cannot delete your Personal Data where:

  • we are required to have it by law
  • it is used for freedom of expression 
  • it is used for public health purposes
  • it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing
  • it is necessary for legal claims. 

Right to restrict what we use your Personal Data for

You have the right to ask us to restrict what we use your Personal Data for where:

  • you have identified inaccurate Personal Data, and have told us of it
  • where we have no legal reason to use the Personal Data, but you want us to restrict what we use it for rather than erase the Personal Data altogether

When Personal Data is restricted it cannot be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.

Right to have your Personal Data moved to another provider (data portability)

You have the right to ask for your Personal Data to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.

This right only applies if we are using your Personal Data with consent and if decisions were made by a computer and not a human being. It does not apply where it would adversely affect the rights and freedoms of others.

Right to object

You have the right to object to processing of your Personal Data which is based on public interest or legitimate interest processing.  We will no longer process the Personal Data unless we can demonstrate a compelling ground for the processing.

Right not to be subject to automated decision-making

You have the right not to be subject to a decision based solely on automated processing.  This right shall not apply where the processing is necessary for a contract with you, or the processing is undertaken with your explicit consent or the processing is authorised by law.

You can make a complaint

You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.

QUESTIONS OR COMPLAINTS

Thank you for reading our Privacy Notice.

Please contact us at [email protected] if you have any questions. 

If we are unable to resolve your concerns, you have the right to contact the supervisory authority in the country where you live or work, or where you consider that the data protection rules have been breached.

The contact details for the Data Protection Commission in Ireland are:

Online Form:
https://forms.dataprotection.ie/contact
Address:
21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Tel:
+353 578 684 800 or +353 761 104 800

Links for other supervisory authorities are provided below:

In Malta, Information and Data Protection Commissioner (idpc)

In UK, Information Commissioner’s Office  

In the USA, there is no single national authority. The Federal Trade Commission has jurisdiction over most commercial entities and has authority to issue and enforce privacy regulations.  State Attorneys generals have a similar enforcement authority. Check the Attorneys General website for your location to understand if you can make a complaint with your local attorney general office.

In Hong Kong, Office of the Privacy Commissioner for Personal Data (PCPD)

In Portugal CNPD – Comissão Nacional de Proteção de Dados

In China, the Cyberspace Administration of China (CAC) (国家互联网信息办公室) CAC

In Japan, Personal Information Protection Commission

In Saudi Arabia Saudi Data and Artificial Intelligence Authority (“SDAIA“)

AMENDMENTS TO THIS PRIVACY NOTICE

We will post any changes to this Privacy Notice on the website and on our job ads in recruitment portals and when doing so will change the effective date at the top of this Privacy Notice. 

In some cases, we may provide you with additional notice of changes to this Privacy Notice, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.