Privacy Notice: Recruitment

Foulath Holding B.S.C (c) (“Foulath”, “us” or “we” or “organization”), understand that your privacy is important to you. We may process your personal data in the capacity as data controllers. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Recruitment Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with organization’s recruiting processes and programs.

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment, and our recruitment drives/ events.

As used in this Privacy Notice, “personal data” means information (name, national ID, passport number, email, phone number, educational and experience details and previous salary details etc.) that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and/or through alternative channels (e.g., via professional recruiting firms, social media). Sensitive personal data may also be collected in the process such as religion, medical records and background checks etc.

We will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail.

By submitting your personal data to us, you acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.
• Your personal data may be transferred and processed outside of Bahrain for the purposes and in the manner specified in this Privacy Notice.
• You are not required to provide any requested information to us, however failing to do so may result in not being able to continue your candidacy for the job for which you have applied.
• All of your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.
• This Privacy Notice does not form part of any contract of employment offered to candidates hired by Foulath.

What Personal data do we collect?

The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which the position is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of personal data we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located.

The types of personal data we collect and process for following purposes when you apply for a role with us includes (but is not limited to):

• Identification data and contact details - such as your name, address, email address, phone number, photograph and other contact information, gender, date of birth, nationality, national identifiers (such as CPR number, passport, driving license number);
• Background information - such as academic / professional qualifications, details included in your CV / resume (which might include details of any memberships or interests constituting “sensitive data”, a term which we define below), criminal records data (for verification purposes, where permissible and required in accordance with applicable law);
• Previous applications / roles - such as data relating to previous applications you have made to us. This could include data on any previous employment history with us;
• Other data you voluntarily provide - throughout the process, including through assessment centers/ exercises, social interaction, meetings, and interviews.

The data we collect and store (a range of examples provided, but not limited to):

	Type of data	Why we collect	How long it will be kept for
1	Identification data and contact details Previous employment and salaries Skills and qualifications obtained Background verification reports Good conduct certificate	This will allow us to make a decision on your suitability for employment/engagement. It will help us to decide which dept. you may be most suitable in.	Data obtained during recruitment will only be kept until either your application has been declined and then destroyed subject to legal requirements. If a job offer is made, a more comprehensive consent form will be issued upon employment.
2	Health records/ disability information This is classed as sensitive personal data and strictly controlled as notification/ preapproval is required to/from the Authority for processing	To ensure we are aware of any medical issues you may have and can make provisions for these if you have a medical requirement at the workplace should there be an offer of employment.	Data obtained during recruitment will only be kept until either your application has been declined and then destroyed subject to legal requirements. If employment is offered, it will be governed by the policies related to employment with the organization.

Generally, during the recruitment process, we intent not to collect or process any sensitive personal data: data that reveals your racial or ethnic origin, religious, political, or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or data concerning your health / sex life unless required by applicable laws or where necessary to comply with applicable laws.

However, in certain circumstances, we may need to collect or request on a voluntary disclosure basis, sensitive personal data for legitimate purposes: for example, data about your racial / ethnic origin, gender, and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government and regulatory reporting obligations, where applicable. Another example where we might request voluntary disclosure of sensitive personal data is about your physical or mental condition and data collected during your health check-up so that we can consider how we might accommodate you during the recruitment process and / or subsequent job role if we recruit you.

You may provide, on a voluntary basis, other categories of sensitive personal data during the recruitment process, for example your CV may state that your interests include activities involving a particular religious group or a group which espouses particular political or philosophical views.

Personal data collected from other sources

1. References provided by referees;
2. Other background data provided or confirmed by academic institutions and training or certification providers;
3. Data provided by recruitment or executive search agencies;
4. Pre-employment health checkup performed only for expatriate applicants/ employees where data is provided by diagnostic centers/ pathological labs; and
5. Data collected from social networks and social media platforms.

Personal Data that we collect automatically

Our cookie policy and data privacy notice are available on the website which will inform you about how we collect certain personal data automatically from your device when you visit our website.

Use of your personal data

By submitting your personal data to us you provide your consent for us to store and process your personal data for legitimate human resources and business management reasons including:

• identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
• recordkeeping in relation to recruiting and hiring;
• ensuring compliance with legal requirements, including diversity and inclusion requirements and practices;
• conducting criminal history checks as permitted by applicable law;
• protecting our legal rights to the extent authorized or permitted by law; or
• emergency situations where the health or safety of one or more individuals may be endangered.

We may also analyze your personal data or aggregated data to improve our recruitment and hiring process and augment our ability to attract successful candidates. We may desire to retain your personal data to consider you for future employment opportunities.

  Data recipients and international data transfers

Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different locations of Foulath. In addition to HR, the hiring function, appointing authority and interview panel individuals performing administrative functions and IT personnel within Foulath may also have a limited access to your personal data to perform their jobs. We have put in place legal mechanisms designed to ensure adequate level of data protection of your personal data that is processed by Foulath, including the transfer of your personal data to countries other than the one in which you reside.

We also share your personal data with other third-party service providers that may assist us in recruiting talent, administering, and evaluating pre-employment screening and testing, and improving our recruiting practices.

We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data. Where required by law, we put in place legal mechanisms designed to ensure adequate level of data protection of your personal data in another country.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

Data retention

If you accept an offer of employment with Foulath, any relevant personal data collected during your pre-employment period will become part of our filing records and will be retained in accordance with specific requirements. If we do not employ you, we may nevertheless continue to retain and use your personal data for a period of time (which may vary depending on applicable regulations/Company policies for retention) for system administration purposes, to consider you for potential future roles, and to perform analysis/ research activities. Thereafter, we will retain a minimum amount of your personal data to record your recruiting activity with us.

If you elect to join a recruiting program, we may retain your personal data to consider you for future employment opportunities and for a period of time specific to that program, unless you decide to opt-out/ unsubscribe prior to such time.

Security

We have implemented generally accepted standards of technical and operational security to protect personal data from loss, misuse, alteration, or destruction.

Sensitive personal data is protected for data in transit by data encryption. In addition to encryption, we have implemented robust network security controls to help protect data in transit. Network security solutions such as firewalls and / or network access control to secure the networks used to transmit data against malware attacks or intrusions.

Only authorized personnel of Foulath and of our third-party service providers are provided access to personal data, and these employees and third-party service providers are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal data.

Your rights

Under certain circumstances, by law you have the right to:

1. 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.
2. Request rectification: Of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. We may need to verify the accuracy of any new data you provide to us.
3. 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, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which means we can continue to process your personal data.
5. Request the restriction of processing: Of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
   1. if you want us to establish the data's accuracy;
   2. where our use of the data is unlawful, but you do not want us to erase it;
   3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
   4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
6. Right to withdraw consent at any time: Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to make a request to access, review, erase, object, restrict, withdraw, or rectify the personal data we have collected about you, please contact our IDPG ( internal data protection guardian ) at privacy@foulath.com.bh.

To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else. We reserve the right to deny your requests where, in the organization’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.

In addition, and where granted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.

We do not make recruiting or hiring decisions based solely on automated decision-making.

Cookies and other tracking technologies

We may use first party and third-party cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) to identify you and your interests, to remember your preferences, and to track your use of our websites. We also use Cookies and Other Tracking Technologies to control access to certain content on our websites, to protect the websites, and to process any requests that you make of us.

Some of our online recruiting activities are hosted by third parties. When you access sites operated by these third parties, they may, consistent with our Cookie Policy, place Cookies or Other Tracking Technologies on your device. You can learn more about our use of Cookies and other tracking technologies by contacting our IDPG ( internal data protection guardian ) at privacy@foulath.com.bh.

Contact

If you have any questions about this Privacy Notice or our Cookie Policy, please contact us at privacy@foulath.com.bh.

Last updated on October 2022