RECRUITMENT PRIVACY NOTICE

Thank you for your interest in career opportunities with ADVANZ PHARMA. ADVANZ PHARMA is responsible for the processing of your personal data as described in this Recruitment Privacy Notice as it decides why and how it is processed, thereby acting as a "controller" in certain jurisdictions. In this Recruitment Privacy Notice, “ADVANZ PHARMA” means the company (or companies) of the Advanz Pharma Group to which you are submitting your job application; "we" or "us" refers to ADVANZ PHARMA. For the purpose of the scope of this Recruitment Privacy Notice, “candidates” mean individuals who apply to an open position with us, or who are contacted for or express interest in employment with us, or who attend a recruitment event or undergo an interview or assessment with us. This includes prospective employees, interns, and contractors (further referred herein as “you”).

This Recruitment Privacy Notice explains the type of personal data ADVANZ PHARMA processes, why we are processing it and how that processing may affect you.

1. WHAT DO WE MEAN BY “PERSONAL DATA” AND “PROCESSING”

1.1. “Personal data” is any information relating to an individual (or from which an individual may be identified, directly or indirectly). This includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. It includes not only facts about you, but also intentions and opinions about you. The categories of your personal data we may process are outlined below.

1.2. “Processing” means any operation or set of operations which is performed on personal data. For example, it includes collecting it, holding it, disclosing it, and deleting it.

2. WHAT PERSONAL DATA DO WE PROCESS AND WHY?

2.1. We process your personal data for the purposes of fulfilling our recruitment requirements. Some of your personal data comes from you. For example, you provide us with your contact details and resume. Other personal data may be generated from references and third-party companies such as recruitment agencies. Your personal data will be seen internally by managers, administrative assistants to HR/hiring managers, payroll, IT, HR and relevant third parties. You are not obliged to provide us with this data. However, should you choose not to do so, this may affect your job application by limiting the information we have to assess it.

2.2. Specifically, we may process some or all of the following personal data categories:

Basic identification data (such as full name, contact information, date and place of birth, nationality, email and/or postal address, landline and/or mobile phone number)
Background check data (such as criminal record)
Education, professional and skills related data (such as employment, educational and training records)
Employment information (such as salary expectation, visa requirement)
Government identifiers (such a social security number, work permit, visa)
Professional experience (such as qualifications, certifications, CV)
Social media data (professional accounts)
Sensitive data (such as health data, diversity data)
CCTV data (when visiting our premises)

3. WHAT ARE THE LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

Under applicable data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts, more than one ground applies. In the context of employee recruitment, we collect and process personal data under Section 2 based on the below legal bases:

In view of the data categories “(i) Basic identification data”, “(iii) Education, professional and skills data”, “(vi) Professional experience and affiliations data”, ADVANZ PHARMA relies on the legal basis that the processing of the personal data is necessary in order to take steps to enter into an employment contract with you.
For the data category “(v) Government identifiers” ADVANZ PHARMA additionally and where applicable relies on compliance with legal obligations. Examples include the legal obligation to verify employment permissions and adherence to its obligations under tax, social insurance and anti-discrimination laws.
In regard to the data categories “(ii) Background check data” and “(ix) CCTV data”, ADVANZ PHARMA relies on its legitimate interest to verify the integrity and reliability of our future employees, ADVANZ PHARMA’s security or the legitimate interests of third parties. Such processing includes the performance of background checks/screenings and execution of interviews with referees that you have provided on our request. We only process your personal data outlined in this category in case we rely on a legitimate interest, and such processing is necessary for the recruitment and application process. Note that we may engage third party service providers for background checks/screenings and that third parties who are part of the administrative and management structure of the entity you are applying to may conduct their own background checks/screenings. In case where we process your personal data for background checks and screening purposes, based on our legitimate interest, and you object to such processing or to provide necessary information, a consequence thereof could be that we cannot further proceed with your application.
In regard to data categories “(vii) Social media” and “(iv) Employment information”, ADVANZ PHARMA relies on its legitimate interest to process personal data contained in CVs or other data provided by the applicant during the recruitment process for recruitment purposes.
In regard to “(viii) Sensitive data”, ADVANZ PHARMA relies on the explicit consent provided by the applicant for information that is not required by law such as diversity and inclusion related data or on the basis of complying with a legal obligation to collect certain sensitive information such as information on health, fitness to work, disabilities and special accommodations.

4. HOW LONG YOUR PERSONAL DATA WILL BE STORED

4.1. If your application is successful and you are hired by us, any relevant personal data collected during the application process will become part of your employee records and data will be kept in your employee file and processed in accordance with our privacy standards for employees.

4.2. If your application is not successful, we will retain your personal data on our files for the purpose of system administration, reporting purposes and potential legal claims. This data is normally deleted 12 months after you have been informed that your application was unsuccessful.

4.3. When obligated to do so under applicable law or when it is necessary for the establishment, exercise, and defense of legal claims, ADVANZ PHARMA may retain your personal data for a longer period of time, as required for the handling of such circumstances. Personal Data collected and/or processed in the context of a dispute are deleted or archived (i) as soon as an amicable settlement has been reached, (ii) once a final decision has been rendered or (iii) when the claim becomes time barred.

5. WHO HAS ACCESS TO YOUR PERSONAL DATA AND HOW DO WE PROTECT IT?

5.1. We may disclose personal data to third parties under certain circumstances. Before doing so, we will assess the lawfulness (including necessity and proportionality) of the disclosure. Such third parties may include:

Other members of our group, specifically any senior management for the business unit and for the group company that is relevant in order to make decisions around hiring and remuneration;
Trusted service providers such as IT service providers which assist with the hosting and maintenance of our websites and digital infrastructure and background check providers;
Third parties who are part of the administrative and management structure of the entity you are applying to;
Regulatory authorities, courts, tribunals, and governmental agencies; and
Enforcement agencies such as police and debt collecting agencies.

5.2. At ADVANZ PHARMA, we prioritize the security and confidentiality of your personal data. When we disclose your information to third parties, whether they are service providers, partners, or other entities, we ensure that stringent measures are in place to safeguard your privacy. These measures include but are not limited to encryption, access controls, contractual agreements, and regular assessments of our affiliates' security practices. We only share the necessary information required to fulfill the purposes outlined in this Recruitment Privacy Notice, and we hold our affiliates to the same high standards of data protection that we adhere to internally. Your trust is paramount to us, and we are committed to maintaining the integrity in handling your personal data.

6. YOUR RIGHTS

a) If you reside in the EU, the UK, or Switzerland, you have the following rights related to your personal data processed by us:

the right to be informed about what personal data we hold about you and how we process your data;
the right to access your personal data as processed by us and, if you believe that any information relating to you is incorrect, obsolete, or incomplete, to request its correction or update;
the right to request the erasure of your personal data or the restriction thereof to specific categories of processing;
the right to withdraw your consent at any time, without affecting the lawfulness of the processing before such withdrawal;
where processing is based on legitimate interest, the right to object, in whole or in part, to the processing of your personal data;
the right to request its portability, i.e. the personal data you have provided to us is to be returned to you or transferred to the person of your choice in a structured, commonly used, and machine-readable format without hindrance from us and subject to your confidentiality obligations; and

the right to object to automated decision-making including profiling, i.e. you can request a human intervention in any automated decision-making process related to processing of your personal data and where such processing is not based on your consent, authorized by law or necessary for the performance of a contract. For the avoidance of doubt, we do currently not make any decisions solely using automated processes.

b) If you reside in the United States, you may have the following rights related to your personal data processed by us:

1. You have the right to know and right to access information about the categories and specific pieces of personal data we have collected about you, as well as the categories of sources from which such data is collected, the purpose for collecting such data, and the categories of third parties with whom we share such data.

2. You may also request a copy of the personal data we have collected and, upon request, we will provide this data to you in a structured, commonly used, and machine-readable format.

3. You have the right to request the deletion of your personal data, subject to certain legal exceptions.

4. You have the right to correct your personal data if inaccurate.

5. You have the right to limit the use and disclosure of your sensitive personal data if we use such information to infer characteristics about you.

6. You have the right to opt out of profiling using automated decision-making technology. You may have the right not to be subject to a decision based solely on profiling, except under certain exceptions under local law.

7. The right to opt out of “profiling” under certain circumstances, as defined under applicable law.

8. The right to request a list of the specific third parties to which we have disclosed your personal data.

9. The right to question the result of profiling, where your personal data is profiled in furtherance of decisions that produce legal or similarly significant effects concerning you. This includes the right to be informed of the reason the profiling resulted in the decision, be informed of what actions you might have taken and can take to secure a different decision in the future. You also have the right to review the personal data used in the profiling and have the data corrected and the profiling decision reevaluated based upon any corrected personal data.

10. You have the right to not be discriminated against for exercising any of these rights.

Your personal data is not sold and not shared for targeted advertising purposes.

Appeals. You have the right to appeal a denial of your request by contacting us as described in the notice of denial.

c) You may under certain circumstances authorize another individual or a business, called an authorized agent, to make requests on your behalf. We must verify your identity (or the identity of your authorized agent) before responding to your request. We may verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity. We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

d) For a data subject request, you can contact us at: enquiries@advanzpharma.com.

7. ACCURACY

We take reasonable steps to ensure that personal data we process is accurate, complete, and up to date. Please note that you have a shared responsibility with regard to the accuracy of your personal data. Please notify ADVANZ PHARMA immediately of any relevant changes to the personal data relevant to your application process.

8. SECURITY

ADVANZ PHARMA takes precautions to protect personal data from unlawful or unauthorized processing and against the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data. We have taken appropriate technical and organizational measures to protect the information systems on which your personal data is stored, and we require our third-party service providers to protect your personal data by contractual means.

9. COMPLAINTS

9.1. If you have any questions or concerns on how we process and use your personal data, please contact us using the following details: Advanz Pharma Services (UK) Limited, Dashwood House, 2nd floor, 69 Old Broad Street, London, EC2M 1QS or you can email us at enquiries@advanzpharma.com.

9.2. If you believe your personal data has been processed inappropriately, you have the right to complain to a competent data protection authority about our processing of your personal data. For EU residents, you can find a full list of EU data protection authorities here: EU Data Protection Authorities

10. SCOPE AND CHANGES

10.1. This Recruitment Privacy Notice does not form part of any contractual relationship between ADVANZ PHARMA and a job applicant.

10.2. ADVANZ PHARMA reserves the right to continuously amend, update and modify this Recruitment Privacy Notice.

You may contact us at:

Advanz Pharma Services (UK) Limited, Dashwood House, 2nd floor, 69 Old Broad Street, London, EC2M 1QS; email: enquiries@advanzpharma.com.

California residents may also contact us at this toll-free number: +18333350881.

Effective Date: 4^th December 2024

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