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Applicant privacy notice

The Norstella Group

Any reference to “we”, “us”, “our” and “the Company” is to the Norstella Group (“Norstella”). The legal entity identified in any communication we have with you will be the data controller of your personal information and references in this notice to Norstella should be read as referencing that entity. You can contact us at privacy@norstella.com for more information about how we process your personal information, including how to exercise your applicable rights as a data subject.

The Norstella Group means the entity with which you communicate during the recruitment process and all other legal entities within the Norstella group under common control with this entity.

This notice

This Applicant Privacy Notice applies to anyone applying for a position or being considered for employment by Norstella. It describes the categories of personal information we may process about you, how your personal information may be processed and how your privacy is safeguarded during the job application and recruitment process. It’s intended to comply with our obligations to provide you with information about the Company’s processing of your personal information under applicable privacy laws.

  • The term “applicant” refers to anyone who is applying to work for Norstella, whether as an employee, worker, sessional workers, apprentice or volunteer
  • The term “process” or “processing” refers to any operation or set of operations which is performed on personal information or on sets of personal information;
  • The term “personal information” means any information which relates to an identified or identifiable, living individual that directly or indirectly references one or more factors specific to their physical, physiological, mental, economic, cultural, or social identity;
  • The term “sensitive personal information” means personal information that reveals information about a living individual’s physical or mental health, racial or ethnic origin, political or religious views, trade union membership, sexual orientation, genetic information, biometric information, commission or alleged commission of crime or related proceedings, and, in some countries, financial information.

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Norstella processes the personal information you voluntarily submit to us when you apply for a position through an online job site, via email, in interviews or in other ways during the recruitment process.

We may also process information about you that we collect from other sources (for example, third party recruitment sources, via background checks with your previous employers, references supplied by former employers, the educational institutions you attended, and/or background checks conducted by a third-party).

We may process some or all of the following types of personal information and sensitive personal information about you during the recruitment process:

  • Your name, address and contact details, including email address and telephone number;
  • Checks for eligibility to work in the in the regions in which we operate as required by immigration laws, such as passport and visa documentation;
  • Details of your qualifications, skills, experience and employment history;
  • Formal identification documentation relating to you, such as a passport or driving license, to verify your identity (including your date of birth);
  • Any interview notes made by us during or following an interview with you;
  • Information about your current level of remuneration, including benefit entitlements;
  • Where required by local law, information about your entitlement to work in the country where we are hiring;
  • Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
  • With your consent as required under applicable laws, we may process sensitive personal information (such as health information or information about your race and ethnicity). If we process this information, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. In such circumstance, your consent is not a condition to our processing of your application.

We will not use your personal information for other purposes, nor share it outside of Norstella except as specified in this notice. We will process your personal information only as part of our recruitment process, including to evaluate your suitability for a position, respond to your application, improve our recruitment process, comply with any applicable procedures, laws and regulations and for human resources analysis purposes.

If your application for employment is successful, we will transfer your information to our internal human resources systems and use it for the purposes of your employment with us. Your personal information will then be subject to our Employee Privacy Notice.

If you are located or reside in a jurisdiction that requires a legal basis for processing personal information (such as the EEA, EU or UK), Norstella has a legitimate interest in processing personal information during the recruitment process and for keeping records of the process. Processing personal information of applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may seek your consent to allow us to process sensitive personal information as explained above. We may also need to process data from job applicants to respond to and defend against legal claims.

If you have questions about or require further information concerning the legal basis on which we process your personal information, please contact privacy@norstella.com.

Your personal information will be shared with our employees and contractors whose roles require access to it. These primarily include hiring managers and the human resources professionals assigned to manage the evaluation of candidates, technical personnel who support our applications and systems, and those that carry out systems maintenance.

Your personal information may be shared with selected third-party vendors that provide services in areas such as background checks, candidate management, facilities management, web analytics and IT services. These vendors may only process your personal information on our behalf and according to our instructions and are required to safeguard your information and rights to the same standard as set out in this Applicant Privacy Notice. Your personal information may also be transferred to;

  • Former employers in order to obtain references;
  • A third party as a result of any merger, acquisition, or similar corporate event involving Norstella;
  • Law enforcement or government authorities where they have followed due legal process to request us to disclose the information.

If you are applying for a senior management position with us, we may share your personal information with our investors.

The length of time for which we retain your personal information is determined by Norstella’s ongoing legitimate business need to carry out the purposes described in this Notice or as otherwise required by applicable law as set out in our retention policies and schedules (including when you have speculatively applied to us in respect of a role which is not available). We will securely delete your information once the obligation to which we are subject expires or after the period of time specified in our retention policies elapses. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it.

If your application is unsuccessful or you do not accept the job for which you have applied, we will hold your information on file for 6 months from the date the recruitment application process has been closed, unless following an unsuccessful application you specifically consent to us holding it for longer for the purpose of contacting you in the event that any similar job opportunities become available from time to time.

If you are located in the United States and your application is unsuccessful or you do not accept the job for which you have applied, we will hold your information on file for 24 months from the date the recruitment application process has been closed.

If your application for employment is successful, personal information gathered during the recruitment process will be retained during your employment. The periods for which employee information is held will be provided to you in our Employee Privacy Notice.

Norstella is a global business. If you are located or reside in a jurisdiction that places certain restrictions on the transfer of personal information (such as the EEA, EU or UK), your personal information will be transferred to countries with different privacy and data protection laws than your own, including to countries such as the United States.

We protect transfers of personal information outside of the EEA, EU and the UK with legal safeguards that include:

  • The existence of a European Commission and Information Commissioner’s Office adequacy decisions (for example, transfers to Japan);
  • Norstella’s Intra-Group Data Sharing Agreement incorporating Standard Contractual Clauses and the UK Addendum approved by the European Commission and the Information Commissioner’s Office;
  • Transfer Impact Assessments to ensure to assess the potential risk of any international transfers in accordance with applicable law;
  • Standard Contractual Clauses and other contract terms executed between Norstella and third-party service providers who processes personal information on our behalf.

Depending on where you are located or where you reside, you may have certain rights granted to you over your personal information under local data protection and privacy laws. We will honour the requests you make related to your rights as the law requires. This means in some cases, there may be legal or other official reasons that we may not be able to fulfil the specific request you make related to your rights.

These rights differ based upon local data protection and privacy laws but one or more of the following may be available to you:

  • Information and access: You may have a right to know what personal information we hold about you and be given information about how we process or have processed it. You may also have the right to obtain confirmation from us that we process your personal information, and if so, to request access to or a copy of such personal information.
  • Correction: You may have the right to request that we correct inaccurate personal information we hold about you. You may also have the right to have incomplete personal information
  • Erasure/Deletion: You may have the right to request that we erase some or all of your personal information, subject to certain exceptions permitted by law.
  • Restriction: You may have the right to ask us to restrict further processing your personal information.
  • Objection: You may have the right to object that we process some or all of the personal information we hold about you.
  • Data portability: You may have a right to request to receive your personal information in a structured, commonly used and machine-readable format, or, where feasible, to have us transfer your personal information directly to another organization.
  • The right to withdraw consent: You may have the right to withdraw your consent to the processing of your personal information where we rely solely on your consent for processing such information. Your withdrawal will not affect the lawfulness of our processing based on your consent before your withdrawal, and you can always give us your consent again in the future.
  • Automated individual decision-making: You may have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you. We will inform you if automated individual decision-making takes place.
  • Right to lodge a complaint: If you believe that we have infringed your rights, we encourage you to contact us first with our Privacy Team so that we can try to resolve the issue. However, you may have the right to lodge a complaint with an applicable data protection authority.
  • Additional rights for California residents: If you are a California resident, you may have additional rights, including:
  • Right to opt out of sale/sharing of my personal information: Norstella does not sell employee personal information as defined in applicable California law.
  • Do not share or disclose my sensitive personal information: You have the right to limit how your sensitive personal information is disclosed or shared with third parties, subject to certain exceptions.

To exercise your rights as described above, please submit a request by submitting a request here.

We have put in place appropriate technical and organizational security measures to protect the security of your personal information both online and offline including the implementation of access controls, firewalls, network intrusion detection, and use of anti-virus software. These measures vary based on the sensitivity of the personal information we collect, process, and store, and the current state of technology. We also take measures to ensure that third parties that process your personal information on our behalf also have appropriate security controls in place.

In some locations, including the United States, we will invite you to self-identify for race, ethnicity, gender, veteran status, and the existence of any physical or mental disabilities. Submission of this information is voluntary and the refusal to provide it will not affect your eligibility for employment with Norstella and/or the terms and conditions of your employment with Norstella, if hired.

If you choose to provide it, your self-identification information will not be accessible to recruitment staff or hiring managers evaluating your application or suitability for a position.

We may use your self-identification information to meet government reporting obligations, and to manage our own diversity and affirmative action programs. If you are hired, we may transfer the information you provided into our general human resources systems and this information will be kept for as long as necessary to fulfil the purposes we collected it for.

If you have questions or complaints or about our processing of your personal information or this Applicant Privacy Notice please contact our Privacy Team here.

We hope we will be able to resolve any privacy concerns you may have. However, you always have the right to complain to any supervisory authority or other public body with responsibility for enforcing privacy laws in your country. The contact details for the supervisory authority in the country/state in which you are based are available from the Privacy Team.

We may update this Applicant Privacy Notice from time to time and will notify you when any changes are made. This Applicant Privacy Notice was last updated in June 2023.

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