The BVNK entities listed in Schedule 1 provide this privacy notice (the “Privacy Notice”) to you because you are applying to work with one of said entities (“BVNK”, “we”, “our” or “us”) as an employee, worker or contractor (the “Application”). This Privacy Notice sets out the information that must be provided by us to you at the time your personal data is collected by us and applies to all personal data we collect, use and process relating to your Application.
BVNK is the controller of the personal data of prospective employees, workers or contractors, and is subject to applicable data protection laws.
If you have any questions about this Privacy Notice, how we process your personal data, or if you wish to exercise any of your rights as described in this Privacy Notice or under applicable data protection laws, you can contact BVNK’s privacy team (the “Privacy Team”) at firstname.lastname@example.org.
What is personal data?
Personal data means any information relating to you as an identified or identifiable person.
Special category data is information about you, relating to one of the following characteristics: racial or ethnic origin; political opinions; religious beliefs or other beliefs of a similar nature; trade union membership; physical or mental health; and/or sexual orientation or sex life.
Data protection principles
We will comply with applicable data protection laws, which state that the personal data we hold about you must be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- adequate and relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about; and
- kept securely.
What personal data do we collect?
In connection with your Application, we will collect, store, and use the following categories of personal data about you:
- information provided in your curriculum vitae, cover letter or during the interview process including: your name, title, date of birth, age, gender, home address, personal email address, telephone number, education, qualifications and work experience details, remuneration details and references (as applicable);
- information collected or created by us during the recruitment process including: interview notes, test results, immigration/naturalisation records and correspondence between us;
- information about criminal convictions and credit checks: we carry out background and credit checks as part of the recruitment process;
- special categories of personal data including: information relating to disabilities, physical or mental health; race or ethnicity; religious beliefs; sexual orientation; and biometric information in the event you provide us with a photograph on your Application; and
- other types of personal data which may include: address history; employment history including salary and dates of employment; reason(s) for leaving; reference information; work status; visa requirements; eligibility to work; education history; identification number; credit status and supporting documents (for example, a copy of your government issued ID); certificates showing professional qualifications; documents that you provide that verify any gaps in your employment history; and any other personal data you make available.
If you fail to provide us with certain personal data when requested, we may not be able to progress your Application.
How do we collect your personal data?
Personal data is collected directly from you, thirdparty sites (including, but not limited to, publicly available sources such as LinkedIn), employment agencies, job sites, your named references, the Disclosure and Barring Service or other background check providers. We may sometimes collect additional information from third parties including former employers or credit reference agencies. Such personal data is collected during our recruitment process.
How do we use your personal data?
We will process or use your personal data to:
- assess your skills, qualifications, and suitability for the work or advertised role;
- carry out background and reference checks, where applicable;
- assess your right to work in the relevant locations in compliance with immigration rules;
- communicate with you about the recruitment process;
- keep records related to our hiring or recruitment process;
- carry out data analytics including the profiles of those applying for roles with us;
- comply with legal or regulatory requirements, for example the duty to make reasonable adjustments for applicants with disabilities and other disability non-discrimination obligations;
- comply with any specific regulatory requirements from our customers;
- manage the recruitment process, and ensure effective HR, personnel management and business administration;
- monitor equal opportunities; and
- enable us to establish, exercise or defend possible legal claims.
We may process personal data about you in compliance with our lawful bases (see below) and/or where this is required or permitted by applicable law. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.
We will only use your personal data for the purpose for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purposes. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may also process your personal data without your knowledge or consent, in compliance with the above rules, where this is permitted or required by applicable law.
When do we use your personal data?
Under applicable data protection law, we must justify the use of personal data by establishing a “lawful basis” of processing. Below we set out each lawful basis we rely on in relation to your personal data. We will use the information collected from you where:
- it is necessary for us to do so to enter into and manage a contract with you;
- we need to process your information in order to comply with a legal or regulatory obligation; and/or
- we, or third parties, have a legitimate interest to:
- ensure the effective administration and management of the recruitment process;
- ensure we hire a suitable individual for a role; or
- deal with disputes and accidents and take legal or other professional advice or ascertain your fitness to work.
If the collection of any of your personal data is not mandatory (for example, where we collect information on a voluntary disclosure basis for equal opportunities monitoring), we will let you know this before we collect it, as well as the consequences of failing to provide us with this information (if any).
How do we use your special category persona data?
We may process your special categories of personal data to:
- consider whether we need to provide appropriate adjustments during the recruitment process, for example, whether adjustments need to be made during a test or interview;
- ensure meaningful equal opportunity monitoring and reporting; or
- comply with any legal or regulatory obligation.
When do we use your special category personal data?
We may use special categories of personal data where:
- you have provided your explicit consent;
- we need to do so to carry out our legal obligations;
- it is necessary for the establishment, exercise or defence of a legal claim;
- there is a substantial public interest; or
- it is needed to protect your vital interests (or someone else's vital interests) and you are not capable of giving your consent.
Information about criminal convictions
As part of the recruitment process, we may ask you for information in relation to unspent criminal convictions as we carry out criminal background checks. We use this information and these checks:
- to assess your suitability for a regulated role;
- to protect your interests, our interests and third-party interests; or
- because it is necessary in relation to legal claims. We are allowed to use your personal data in this way where it is necessary to carry out our employment rights and obligations.
Retention of your personal data
The periods for which personal data will be stored and the criteria used to determine retention periods or whether personal data can be removed will depend on the information in question, its relevance or sensitivity. However, generally, personal data will be deleted if it has been superseded by other relevant or up to date personal data, if it is out of date, irrelevant or no longer necessary.
Generally, this means that your personal data will be retained until the end of your Application process or working relationship with us plus a reasonable period thereafter once we have communicated our decision to you about whether to appoint you to a role or offer you work. We retain your personal data for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal data in accordance with our data retention policy. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Change of purpose
We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purposes. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may also process your personal data without your knowledge or consent, in compliance with the above rules, where this is permitted or required by law.
Who we may share your personal data with?
We will only share your personal data with the following third parties for the purposes of processing your Application:
- recruitment agencies and platforms, such as LinkedIn and Otta;
- applicant tracking systems, such as Greenhouse;
- background check and online test providers, such as Zinc;
- employee of record, global payroll solution providers or similar service providers (including Deel, Monday.com and Finance Crowd);
- credit reference agencies; and/or
- regulators and competent authorities.
All our third party service providers and BVNK group entities are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your personal data may also be shared and processed by other BVNK group entities, for example where they provide services intra-group, for entering into a contract with you for the provision of our services or to perform obligations under such contract.
Transfers of personal data
Your personal data will be stored on servers located in Ireland.
We may transfer the personal data we collect about you to countries outside the UK for the purposes of administering the recruitment process. For example, we use Greenhouse to receive and manage applications submitted through the website. This information is hosted by Greenhouse in the United States of America.
Where required by applicable data protection laws, your consent to the transfer of your personal data outside your home country will be obtained as part of your Application.
As an international organisation, our authorised personnel may access your personal data in any country in which we operate (see Schedule 1). Therefore, it may be necessary to transfer your details to members of a BVNK group located in countries that may not have equivalent data protection or privacy laws to those which apply in your own country. We may also need to transfer your personal data to third-party service providers located in other countries. Regardless of where your personal data is transferred to, we make sure that your personal data is protected and that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable data protection laws. Those may include: (i) adequacy decisions as issued by the UK Information Commissioner’s Office; and/or (ii) entering into the UK International Data Processing Agreement and/or Addendum to the EU Standard Contractual Clauses, as applicable.
If you would like further details of such safeguards, please notify BVNK’s Privacy Team at the email address above.
Under certain circumstances, by law you have the right to:
- request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes;
- request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
- request the transfer of your personal data to another party; and
- if you want to review, verify, correct or request the erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact BVNK’s Privacy Team in writing.
Right to withdraw consent
You have the right to withdraw your consent for processing at any time. To withdraw your consent, please contact BVNK’s Privacy Team. Once we have received notification that you have withdrawn your consent, we will no longer process your Application and, subject to our data retention policy, we will dispose of your personal data securely.
You also have a right to complain to a supervisory authority, in particular:
- a list of European Union data protection authorities can be found here;
- the United Kingdom’s data protection authority’s contact details can be found here;
- the South African data protection authority’s contact details can be found here; and
- the Singapore data protection authority’s contact details can be found here.
Please note this notice has been drafted in respect of UK and EEA data privacy requirements. To the extent any other local applicable data protection laws conflict with the contents of this privacy notice, such applicable data protection laws shall prevail.
Changing this Privacy Notice
We reserve the right to update this Privacy Notice at any time. We may also notify you in other ways from time to time about the processing of your personal data.
- United Kingdom
BVNK SERVICES LIMITED
Company Number: 13549382
Registered address: 89 Charterhouse Street, Third Floor, London, England, EC1M 6PE
WIREDIRECT SERVICES LIMITED
Company Number: 13150066
Registered address: 89 Charterhouse Street, Third Floor, London, England, EC1M 6PE
SYSTEM PAY SERVICES LTD
Company Number: 11621763
Registered address: 89 Charterhouse Street, Third Floor, London, England, EC1M 6PE
System Pay Services Lithuania, UAB
Company Number: 306302535
Registered address: Mėsinių g. 5, LT-01133 Vilnius, Lietuva, Lithuania
SYSTEM PAY SERVICES (MALTA) LTD
Company Number: C66961
Registered Address: 68 Northfields, Penthouse 9, Independence Avenue, Mosta MST9026, Malta
BVNK Services Nigeria Limited
Company Number: 1755367
Registered address: Okotie Eboh, Off Awolowo Road, Ikoyi, Eti-Osa, Lagos State, Nigeria
System Pay Services (Singapore) Pte. Ltd
Company Number: 202313806H
Registered address: 160 Robinson Road, #14-04 Singapore Business Federation Center, 068914, Singapore
- South Africa
System Pay Services SA (Pty) Ltd
Company Number: 2019/222842/07
Registered address: Office 103, First Floor, North Wing, Granger Bay Court, V&A Waterfront, 8002
System Pay Services Solutions Spain, S.L.U.
Company Number: B16987679
Registered address: a. de Europa 19, 3A, Parque Empresarial La Moraleja, Alcobendas, Madrid, Comunidad de Madrid, 28108, Spain