Applicant Privacy Policy

Last updated: 22 May 2018

Scope of application

This privacy notice applies to the processing of personal data, which means information about an
identifiable individual (“you”), that Fly Victor Limited (“Fly Victor”, “we”, “us” or “our”) collects about
candidates for employment. It also describes your data protection rights, including a right to object
to some of the processing which Fly Victor carries out. More information about your rights, and how
to exercise them, is set out in the ‘Your choices and rights’ section.

We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.

What personal data we collect

Personal identification and communication information: your name, home address, phone number; email address; date of birth, gender, national insurance number and immigration status;

Application-related information: curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, reference contact information, position preferences, willingness to relocate, desired salary, interests and aspirations; and

Sensitive information: for example, information about your health and disabilities where we need to make any reasonable adjustments.

Why we collect, use and store this personal data

We collect, use and store your personal data for the reasons set out below.

Where this is necessary for Fly Victor to enter into an employment contract with you.

  • To make informed decisions on recruitment and assess your suitability for the role.
  • To reimburse you for any agreed expenses incurred in the application process.

Where necessary for Fly Victor’s legitimate interests, as listed below, and where our interests are not overridden by your data protection rights.

  • To improve our recruitment process and activities.
  • To contact you about future career opportunities at Fly Victor.
  • Protecting our legitimate business interests and legal rights, including, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.
  • To analyse and monitor the diversity of the workforce in accordance with applicable laws. This includes, for example, compliance with equal opportunity employment laws.

Where we require the information to enter into an employment or services contract with you, or where we are required under applicable employment, social security, social protection or other laws applicable to us, the provision of information is mandatory. If you do not provide the relevant data, then we may not be able to conclude an employment contract with you or we may need to withdraw your offer of employment. All other provision of your information is optional. Where you do not provide the relevant data for in these circumstances, the consequences will be explained to you at the time.

How we share your personal data

Your personal data will be shared with companies providing services under contract to Fly Victor as part of the recruitment process, such as psychometric tests or assessment tests.

Your personal data also will be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.

In the event that a Fly Victor business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Your choices and rights

You have the right to ask Fly Victor for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Fly Victor processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.

How long we retain your personal data

If you are successful: we will retain your personal data only for as long as we need it for Fly Victor’s legitimate interest in accordance with applicable law, for the purposes of the recruitment process and, once this process is finished, for an appropriate period so as to be able to deal with any legal claims linked to the application process. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you. If you become a Fly Victor employee, personal information you provide will become a part of your employee file and may be used later for the management of the employment relationship.

If you are not successful: we will retain your personal data for the appropriate period so as to be able to deal with any legal claims linked to the application process. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you. We will ask you if you wish so we can keep you in mind for future recruitment processes. If you would prefer that we did not keep your details on file, please let us know.

International transfers

Your personal data will be processed in or accessed from jurisdictions outside the European Economic Area (“EEA”) or Switzerland by members of the Fly Victor group and certain service providers in jurisdictions that do not have equivalent data protection laws to those in the EEA for the purposes outlined above.

When we transfer your data within the Fly Victor group, we make use of standard contractual clauses, which have been approved by the European Commission. When we transfer your data to organisations outside Fly Victor, we also use European Commission-approved standard contractual clauses to safeguard the transfer, unless we transfer personal data to a third party that has implemented Binding Corporate Rules or which uses the EU-U.S. or Swiss-U.S. Privacy Shield, in which case we may rely on one of those mechanisms to safeguard the transfer. For further information, including how to obtain a copy of the documents used to protect your information, please contact us as described in the Contact Us section below.

Updates to this privacy notice

This privacy notice may be updated periodically. We will update the date at the top of this privacy notice accordingly and encourage you to check for changes to this privacy notice, which will be available at [LINK]. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this privacy notice, as required by applicable law.

Contact us

The data controller for your personal data will be Fly Victor.

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact Stephen Jones (Group General Counsel) at stephen.jones@alyssum.com.

Version history

1.0 22 May 2018 Stephen Jones GDPR compliant
2.0 22 May 2018 Stephen Jones GDPR compliant