Introduction

When you apply for a role with VFS Global (“Company”, “VFS Global”, “we” or “us”, as defined below), your personal data will be processed as part of the job application process.

This document applies to candidates for jobs or roles at VFS Global and describes how we collect and use your personal data when you apply for a job or role at VFS Global. This is a global notice and applies alongside any other relevant privacy notice or other documentation in place in the country in which you are applying for employment.

VFS Global will process your personal data in accordance with our internal policies and applicable privacy laws in the country where you are applying for employment.

This document does not form part of any contract of employment or other contract to provide services. This document can be updated at any time. Any changes we make to our privacy notice in the future will be posted on this document. Please check back frequently to see any updates or changes.

DEFINITIONS

Company / VFS Global / Hiring Entity:
VFS Global AG and its subsidiaries.

Client Government/s:
governments and/or their diplomatic missions for which VFS Global provides services.

Data Protection Policy:
The Company’s policy in relation to obtaining, handling, processing, transportation and storage of personal data. Please be aware that the Data Protection Policy will be updated periodically in accordance with law requirements.

Personal data:
any information relating to you as a candidate during the hiring process with VFS Global.

VFS Recruiting Policy:
The Company’s policy in relation to job application process.

VFS Policies:
the Data Protection Policy and VFS Recruiting Policy as applicable to candidates during the job application process.

CONTROLLER

VFS Global is the controller of your personal data.

This means that VFS Global is responsible for deciding what personal data we collect and how and why it is processed in relation to your application to VFS Global. This will be performed in accordance with VFS Policies and applicable privacy laws in the country where you are applying for employment.

Further details of the personal data we collect, where we get it from and what we do with it are set out in sections 4, 5 and 6 of this document.

DATA PROTECTION OFFICER (DPO)

The Company’s DPO is an independent person who is responsible for ensuring that your personal data is processed legally and in accordance with this document, VFS Policies and applicable privacy laws in the country where you are applying for employment.

PURPOSE OF PROCESSING YOUR PERSONAL DATA

We cannot administer your application without your personal data.

We process your personal data for particular purposes in connection with our recruiting process, your possible future employment or engagement with us, and the management and administration of our business. We may collect, use and store your personal information for the following reasons:

• complying with right to work compliance obligations in accordance with the laws of the country in which you are applying for employment
• complying with equality and non-discrimination compliance obligations (and, if and where applicable, relevant diversity and inclusion laws and policies) under the laws of your country and/or applicable requirements of certain clients and/or governments (and their associated procurement departments) to the extent permissible under applicable law, including managing and administering our equal opportunities reporting where we are required to do so in your country
• managing our health and safety compliance obligations in accordance with the laws of the country in which you are applying for employment
• determining whether any adjustments (i.e. accessibility adaptations) are necessary to enable you to carry out your role
• responding to employment and industrial relations matters where permitted by applicable law, including criminal investigations, grievances, arbitrations, negotiations, elections and strikes
• supporting the sale, transfer or merging of part or all of our business or assets, or in connection with the acquisition of another business
• making a job offer to you and entering into a contract of employment with you
• communicating with you and providing you with information in connection with your application from time to time
• feedback on our recruitment activities and employee selection processes to enable us to improve our ability to select the best candidates for positions in the business
• testing candidates, their knowledge, abilities and approach
• administering your application for a job with us and considering your suitability for the relevant role
• keeping records related to our hiring processes
• administering our insurance policies
• monitoring the security of the Company’s physical premises and systems, networks and applications
• investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting the Company’s compliance with relevant legal and regulatory requirements in the country in which you are applying for employment and compliance with best practice and good governance responsibilities
• obtaining legal advice for enforcement and compliance
• benchmarking, research and analysis
• identifying and authenticating candidates and other individuals
• responding to requests or non-binding search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities and related parties
• emergency use, so we can get you the help you need and deal with the emergency services
• health monitoring in an epidemic, pandemic or other situation where we are permitted or required to obtain this information under the local law in the country in which you are employed

Please note that the ways in which VFS Global uses your personal data will vary depending on the country in which you are applying for employment and will be carried out in accordance with the laws of your country.

LEGAL BASIS FOR PROCESSING

We are required by law to always have a permitted reason or justification (called a “lawful basis”) for processing your personal data. The list below sets out the different purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.

We need to have a legal basis for using your personal information for the purposes set out in this document. We consider that our legal bases are as follows:

• our use of your personal information is necessary for the performance of or entering into an employment contract with you; or
• our use of your personal information is necessary for VFS Global to comply with a legal obligation (for example, providing your personal information to HMRC, complying with health and safety requirements, conducting legally required checks on your right to work in your country); or
• where we have obtained your consent (if and where such consent is appropriate, given the specific circumstances of the processing); or
• where any alternative lawful exception or derogation applies (such as, for example, where we may be processing personal data for the prevention or detection of crime)
• where (a) to (d) inclusive do not apply, the processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party.

We are required by law to treat certain categories of personal data with even more care than usual. These are called sensitive or special categories of personal data and different lawful bases apply to them. We have set out below the different purposes for which we process your special category personal data:

• where we reasonably need to do so in order to comply with our legal obligations as an employer and/or to exercise specific rights conferred on us by law and in line with this document;
• where we need to do so in order to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards;
• where it is in the public interest, such as for equal opportunity monitoring (to the extent permitted by the laws in your country);
• where we need to do so in relation to legal claims;
• where the data processing is necessary to protect your or another person's vital interests (such as an emergency contact information in the event of an emergency at work) and you are not capable of giving your consent or where you have made the information public; and/or
• in limited circumstances, where you have given us your explicit consent.

Please note that the lawful basis VFS Global relies upon to process your personal data and special category personal data will vary according to the country in which you are applying for employment.

If we have asked for your consent to collect and use certain types of personal information, you may withdraw your consent at any time, by contacting dpo@vfsglobal.com.

Please note that where we have indicated above that our processing of your personal data is either:

• necessary for us to comply with a legal obligation; or
• necessary for us to take steps, at your request, to potentially enter into an employment contract with you,

and you choose not to provide the relevant personal data to us, we may not be able to enter into a contract of employment or engagement with you.

6. INFORMATION COLLECTED BY VFS GLOBAL

The following categories of personal data may be collected, held, and processed by VFS Global in relation to your application. You will be able to see and check the correctness of your information and update the same as required in https://career2.successfactors.eu/career?company=vfsglobalsP

Please note that the collected information, as listed below may vary depending on the requirements and restrictions of the local laws in the country in which you are applying for employment with VFS Global.

WAYS OF COLLECTING PERSONAL DATA

VFS Global may collect your personal data in the following ways:

• When creating an account in the Company’s careers portal;
• When submitting your application to VFS Global;
• Details from your previous employer (for instance in a reference);
• Public sources, such as publicly available directories and online resources;
• In accepting our employment offer.

We also create some personal data ourselves, for instance, through notes about your interview or application.

YOUR RIGHTS

You have the following rights with regards of your personal data:

• the right to be informed about the collection and use of personal data by VFS Global;
• the right of access to the personal data VFS Global holds about you;
• the right to rectification if any personal data VFS Global holds about you is inaccurate or incomplete;
• the right to be forgotten (where applicable);
• the right to restrict the processing of your personal data. Please be aware that this may impact the functions that VFS Global can perform in relation to your application;
• the right to data portability (obtaining a copy of the personal data to reuse with another service or organization);
• the right to object to VFS Global using your personal data for particular purposes. Please be aware that this may impact the functions that VFS Global can perform in relation to your application;
• the right to have a human review of automated decision making and profiling (where applicable).

It is important to note that those are not absolute rights and are subject to limitations or exemptions under the local law in the country in which you are applying for employment.

If you want to exercise your rights, please contact the Company’s DPO at dpo@vfsglobal.com or by contacting VFS Global through Data Subject Access Rights Form.

TRANSFERING PERSONAL DATA

Sometimes we need to disclose your personal data to other people.

Inside the VFS Global group
We are part of the VFS Global group of companies. Therefore, we may need to share your personal data with other companies in the VFS Global group (for example, for shared services/division of functions) and key parental decision making and reporting purposes. Where any group companies process your personal data on our behalf (as our processor), we will make sure that steps are taken to protect the confidentiality, security and privacy of your personal data.

Outside the VFS Global group
From time to time we may ask third parties to carry out certain business functions for us. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to other people, we will make sure that they have appropriate security standards in place to make sure your personal data is protected and we will enter into a written contract imposing appropriate security standards on them. Examples of these third party service providers include service providers and/or sub-contractors, such as HR providers, and our IT systems software and maintenance, back up, and server hosting providers.

In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right for the purposes set out above. For example, our recruitment consultants and agencies, or if we work with third parties who carry out tests to assess suitability.

We have set out below a list of the categories of recipients with whom we are likely to share your personal data:

• consultants and professional advisors including legal advisors and accountants;
• courts, court-appointed persons/entities, receivers and liquidators;
• companies that provide products and services to us, such as: human resources services, pre-employment checks, training and occupational health assessments, and medical professionals and recruitment agencies;
• trade associations and professional bodies;
• recruitment portal provider;
• recruitment agent;
• candidate test provider;
• insurers; and
• governmental departments, statutory and regulatory bodies including the Department for Work & Pensions, Information Commissioner’s Office, the police and His Majesty’s Revenue and Customs.

We may also share your personal data with third parties, as directed by you.

Your personal data may be transferred outside your country, for the purposes mentioned above in this document. Although data protection laws in some jurisdictions may not provide the same level of protection for your personal data as is provided under the laws in your country, we will only transfer your personal data abroad as permitted by law. This includes allowing transfers:

• to a country which is recognized as already ensuring an adequate level of protection for personal data;
• where appropriate safeguards are put in place with the recipient to protect your personal data, such by use of the official approved standard contractual clauses used for this purpose (called the International Data Transfer Agreement, or the UK Addendum) - please contact dpo@vfsglobal.com if you wish to obtain a copy of these;
• where the transfer is necessary for a permitted reason specified in data protection law; or
• where you consent to the transfer.

AUTOMATED DECISION MAKING

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. If we ever make any decision through a solely automated process, you have the right to ask us for a review of how we made our decision and/or to appeal the decision. We would explain how to request this at the point we communicate the decision to you.

SECURITY

We are committed to protecting personal information from loss, misuse, disclosure, alteration, unavailability, unauthorised access and destruction and we take all reasonable precautions to safeguard the confidentiality of personal information, including through use of appropriate organisational and technical measures.

Where we have given you (or where you have chosen) a password which enables you to access the VFS Global careers portal or any other portal or account, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.

For the security and safety of our clients and staff, the Company operates CCTV on some of its sites. All areas under CCTV surveillance are clearly signposted in accordance with the laws of your country.

DATA RETENTION

We will only retain your personal data as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting contractual requirements.

We will keep your personal data during the recruitment process and afterwards for as long as is necessary in connection with both our and your legal rights and obligations. If your application is unsuccessful, we will keep your personal data for six months. If your application is successful, we will move relevant details to your employment file and it will be kept in line with our employee data retention periods (as are explained in our employee privacy notice and VFS Policies which will be provided to you before your employment commences).

Your personal data may be retained following completion of such processing where permitted by law, including:

• to comply with any applicable laws or regulations;
• to deal with any legal or other type of dispute; and
• where we are asked by you or a regulatory authority to keep your personal data for a valid reason.

13. RIGHT TO LODGE A COMPLAINT

In the event of questions related to the processing of your personal data you can contact by email VFS Global Data Protection Officer at dpo@vfsglobal.com

You also have the right to lodge a complaint with the applicable regulator in your country.