TruePay Recruitment Privacy Policy

This Recruitment Privacy Policy (“Recruitment Policy”) describes how TruePay collects, uses, and processes your personal data for recruitment-related activities. 

This Recruitment Policy identifies TruePay’s principles for protecting the personal data of our candidates and requirements we must follow to ensure compliance with applicable laws and regulations, including the General Data Protection Regulation (the GDPR).

It is important that you read this Recruitment Policy so that you are fully aware of how and why we are using such information. We take privacy and the protection of your data very seriously and are committed to handling the personal information of those we engage with responsibly and in a way that meets the legal requirements of the countries from which we operate.

1. Responsible entity

The responsible entity for the collection, processing and use of personal data is the TruePay parent or subsidiary company (“Recruiting Companies”) which is offering the role that you may apply for.

The table below displays information about our Recruiting Companies and should you have any questions you can email us at candidate-privacy@truepay.co.

Locations

TruePay Entity

Nigeria

TruePay Technologies Ltd 34 Awolowo Road, Ikoyi, Lagos State

United-Kingdom

TruePay Ltd 20-22 Wenlock Road, London, England, N1 7GU

2. What personal data does TruePay collect and from where?

Personal data, or personal information, means any information about an identified or identifiable individual. It does not include anonymous data, which cannot be linked back to the individual. We will collect and process the following personal data about you:

• • Name, email address, telephone number and other contact information;
  • Resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and recruitment process;
  • Information provided by you during interviews and phone-screenings you may be asked to participate in;
  • Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
  • Details of how you heard about the position you are applying for;
  • Reference information and/or information received from background checks (where applicable), conducted by third parties which are engaged by TruePay, once you have accepted an offer;
  • Information relating to any previous applications you may have made to TruePay and/or any previous employment history with TruePay;
  • Information about your educational and professional background from publicly available sources, including online, that we believe is relevant to your application or a potential future application, including your LinkedIn profile; 
  • Information related to any assessment you may take as part of the interview screening process;
  • Right to work in the country where the role you applied to is based and immigration status (evidence of such will be asked only at a later stage if you successfully pass the interview and we make you an offer);
  • Technical data on how you interact with our recruitment tools and services including URL, IP address, cookies, and how you interact with and browse away from the page; and
  • If you use our jobs alerts or save for later features, only your email address will be collected.

Special categories of personal data 

Our application form contains some voluntary questions that are intended to help us learn about the various identities and backgrounds that make up the candidates applying to TruePay, for example, What gender identity do you most closely identify with? Providing us with this information will help us take actions that support under-represented groups and make sure our hiring process is inclusive and fair for everyone.

The questions may be sensitive to some, so all survey responses are secure and optional. All data will be handled anonymously, aggregated and not linked to you. It will in no way impact your opportunity to work for us within the application or hiring process. There are no obligations to answer these voluntary questions. If you decide not to participate you can select ‘I don’t wish to answer’ under each question.

If you choose to answer these questions, the following data will be collected: gender, medical or health information (specifically disability) and/or your racial or ethnic origin. 

Other types of personal data with special rules

Once you have accepted an offer: criminal records and credit checks as part of background checks where required by and in accordance with applicable laws. 

How TruePay collects your personal data

We collect most of this information from you directly, through application forms and CVs/resumes, from correspondence with you, or during interviews, meetings or other technical or capability assessments.

We also collect information about you from other people or organizations, including from your referees, previous employers, recruitment agencies, publicly available sources (including LinkedIn and Hired), background verification providers and official issuing bodies of ID documents and criminal records.

3. Why are we collecting your data?

We process your personal data only for the following purposes related to recruitment:

• • Select the best candidate for a specific position based on the job description;
  • Conduct pre-employment background checks, as permitted or required by and in accordance with local law;
  • Analyse and monitor the diversity of applicants and candidates;
  • Manage the performance of our recruitment process;
  • Retain applications for future positions that may become open, unless you object;
  • Search for suitable candidates either via our internal recruitment resources or by using third parties;
  • Protect our legal rights, including in the course of legal proceedings, obtaining legal advice, and establishing or defending legal claims;
  • Comply with our obligations under employment and social security law, including carrying out right-to-work checks;
  • Comply with our equality and anti-discrimination obligations where required by and in accordance with applicable laws;
  • Store your data when an application has been made on your behalf (including by a referral or a recruitment agency);
  • Process sensitive data allowing us to take actions that support underrepresented groups and ensure our hiring process is inclusive and fair for everyone; 
  • Save your application for you to complete at a later time;
  • Send you job alerts when you have subscribed to this feature;
  • Send you by email a link to a job advertisement you’re interested in so you can come back to it and start applying later. 

If EU, UK, Brazil or UAE ADGM data protection laws apply to the processing of your personal data, below is our legal basis for processing it:

We collect and process your personal data where it is necessary in order to take steps, at your request, prior to us potentially entering into a contract of employment with you. We may also seek your consent to process your personal data in specific circumstances, or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your data to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates.

Where we have asked for your consent to the collection, processing and transfer of your personal data for a specific purpose, you may withdraw that consent at any time by notifying candidate-privacy@truepay.co. If you withdraw your consent to TruePay processing your data, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so by law. Withdrawal of consent will not affect the legality of any processing which had previously taken place under that consent.

4. Who does TruePay share your personal data with? 

Your personal data may be shared:

• • Across TruePay between the different teams taking part in your recruitment process; 
  • With third party service providers which provide us with services to store and manage applications, schedule interviews, and perform technical assessments of applications; 
  • With background checks providers; 
  • With recruitment agencies if your profile was originally provided by them;
  • With law firms or other advisors helping us to protect TruePay’s legal rights.

Where personal data is disclosed to third parties, appropriate safeguards are implemented to ensure that the data is processed legitimately and protected appropriately. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

TruePay may provide personal data to third parties. This is usually in cases were external tools are used to process your application, schedule interviews or create employment contracts etc.

Recipients retain and use the personal information from the date of receiving it until the consent is withdrawn or the purpose of the provision is achieved, in any case for no more than one year. 

If you would like further information about who we have shared your data with, you can request this by writing to candidate-privacy@truepay.co.

5. How do we protect your personal data?

We take the safeguarding of your information very seriously. TruePay takes all steps reasonably necessary to ensure that there are appropriate security measures in place to safeguard your personal data. In determining the appropriate security, TruePay takes into account technological developments and assesses the measures in place against the risk of harm that may result from a security breach. The security measures implemented by the company are appropriate to protect against the risks presented by the processing and are put in place to prevent unauthorised or unlawful disclosure as well as to protect against data loss, misuse or alteration of your personal data.

Amongst the steps we take to keep your data secure are:

• • Communication over the internet between you and TruePay’s systems is encrypted using strong asymmetric encryption. This makes it unreadable to anyone who might be listening in;
  • We update and patch our servers in a timely manner;
  • We run a Responsible Disclosure and bug bounty program to identify any security issues in TruePay services;
  • Our technical security team proactively monitors for abnormal and malicious activity in our servers and services;
  • When information about you is not in active use, it is encrypted at rest. This means it’s unreadable without the decryption key;
  • We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards (including obligations to protect any information and applying appropriate measures for the use and transfer of information);
  • We perform regular audits to confirm we remain compliant with our security certifications, such as SOC2. As part of these audits, our security is validated by external auditors;
  • We regularly train our employees about the importance of confidentiality and privacy of personal data;
  • We maintain physical, electronic and procedural safeguards that comply with relevant laws and regulations to protect your personal information from unauthorised access;
  • We restrict access to your personal information to those employees of TruePay, agents, contractors and other third parties who have a business reason for knowing such information. They will only process your personal data on our instructions.

6. International data transfer

When transferring your data to third parties who may be located outside of the country where the role you are applying to is based, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Recruitment Policy. We will also ensure that appropriate safeguards are in place. 

If you are located in the EEA or UK: We may transfer your data to and store it in countries outside the UK and European Economic Area (“EEA”) which do not offer an equivalent level of protection to your country. It may also be processed by staff operating outside the UK and EEA who are taking part in your recruitment. For transfers from the EEA and UK to a destination outside the EEA and the UK, transfers are made subject to appropriate legal safeguards, including under European Commission and/or UK approved Standard Contractual Clauses, or by relying on other data transfer mechanisms which may be available under applicable data protection laws.

7. Profiling and automated decision making

While fulfilling the application form, you may be asked eligibility questions, for example do you have a working visa for this country? If you don’t meet the eligibility criteria, your application might be automatically declined. If this happens, you will be notified and offered the opportunity to provide further information, challenge the decision and request a manual review. 

Except in the case of eligibility questions, we do not use profiling or automated decision-making processes that have a legal or other significant effect on you as part of our recruitment. If you feel that such processes may have impacted you, please contact us at candidate-privacy@truepay.co.

8. Cookies

We use small files (known as cookies) to give you a better browsing experience, improve the quality of our website, and keep our marketing costs down. For detailed information on cookies and other technologies we use and the purposes for which we use them, see our Recruitment Cookie Policy.

9. Data retention

If you are offered and accept employment with TruePay, the information collected during the application and recruitment process will become part of your employee record. Details regarding this processing will be provided to you in another privacy notice once you have accepted the offer.

If your application is unsuccessful (or you withdraw from the process or decline our offer), we will store your data for a period of one year after you have been rejected from, withdrawn from or declined applications.

After a one-year period, any identifiable data will be aggregated, so your application data can no longer be associated with you. We do this for reporting purposes only to help us better understand, analyze and improve our recruitment process. 

When you save your application to complete it later, we will store your email and any data you have filled in so far for seven (7) days, after which we will delete the incomplete form from our system.

10. Your rights

Subject to applicable laws, you may have certain rights regarding the information we hold about you. Your rights can be exercised in accordance with the relevant data protection legislation. 

If you are located in Australia, Hong-Kong, Malaysia or Philippines: you have the right to request access to your personal data and have incorrect or incomplete personal data rectified.

If you are located in the EEA, the UK, Brazil, China, or UAE-ADGM: you have the right to request access to your personal data, to have them rectified or erased, to object to their processing or to have access to them restricted. You may also have the right to receive a copy of your personal data in a machine-readable format, to have your personal data sent to another party and/or the right to not be subject to any decision that significantly affects you and is taken solely by automated processing, including profiling.

We will process all requests in a timely manner in line with applicable laws. You should make such requests in writing to candidate-privacy@truepay.co. We may ask you for additional information to confirm your identity and for security purposes before actioning your request.

In certain instances, local data protection and privacy laws may allow us to legitimately and properly refuse your requests, for instance, to protect the rights of third parties or to preserve the confidentiality of management deliberations, or if you have asked us to delete information which we are required by law or have compelling legitimate interests to keep.

If you have any concerns, or you believe that your data protection or privacy rights have been infringed, you may lodge a complaint with your relevant supervisory authority or other public body with responsibility for enforcing privacy laws.

Locations

Local Data Protection authority

Brazil

Autoridade Nacional de Proteção de Dados at www.gov.br/anpd

EEA

List and contact details of European Supervisory Authorities by country can be found here.

UAE – Abu Dhabi Global Market (ADGM)

The Office of Data Protection at https://www.adgm.com/operating-in-adgm/office-of-data-protection/overview 

United-Kingdom

The Information Commissioner’s Office at www.ico.org.uk.

11. Third-party links

This website may, from time to time, contain links to the websites of our partner networks, advertisers and affiliates. Please note that these websites have their own privacy policies and that we do not accept any responsibility for them, so if you follow a link, check these policies before you submit any personal data to these websites.

12. Changes to our Recruitment Privacy Policy

To keep up with changing legislation, best practices and changes in how we process personal information, we may revise this Recruitment Policy at any time without notice by posting a revised version on this website. If we make any substantial updates while you’re being involved in a recruitment process, you will be notified by email.