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Privacy Notice for Staff and Job Applicants

PURPOSE

This privacy notice describes how ACLED collects, uses, and protects personal data relating to job applicants and staff in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

We are committed to handling your personal data lawfully, fairly, and transparently. This notice applies to current and former employees, contractors, and job applicants.

SCOPE

What data do we collect?

Depending on your relationship with us (applicant, employee, contractor), we may collect and process the following categories of personal data:

  1. Identification and Contact Information
  • Full name
  • Date of birth
  • Address
  • Email address
  • Phone number
  • National ID/passport details
  1. Recruitment Data
  • CVs/resumés, cover letters
  • Interview notes and assessments
  • References
  • Right-to-work documentation

     
  1. Employment Data (for staff)
  • Job title, work location, start and end dates
  • Bank account and payroll details
  • Tax and social security information
  • Performance reviews, training records
  • Disciplinary and grievance records
  • Attendance and leave records
  • Emergency contact information

     
  1. Special Category Data (where applicable)
  • Health or disability data (e.g. for sick leave)

How We Use Your Data

  • Processing job applications and communicating with candidates
  • Managing employment contracts, payroll, and benefits
  • Ensuring compliance with tax, labor, and social security laws
  • Monitoring performance and managing training
  • Supporting health, safety, and workplace accommodations
  • Handling disputes, complaints, and legal claims
  • Maintaining company security, including IT systems and building access
  • We do not use personal data for automated decision-making or profiling without human involvement.

Who We Share Your Data With

We only share your data when necessary and always in compliance with GDPR. Your data may be shared with:

  • HR and hiring teams
  • Finance and Ops to support the onboarding and orientation process
  • Payroll providers (including Trinet, Deel, Rippling)
  • IT service providers (Hofy, Marcum)
  • Legal and regulatory authorities (when required)
  • Background check agencies (DISA, Mesh, Checkr)

All third-party processors operate under contracts and are required to comply with GDPR.

Your rights under GDPR 

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

  • the right not to provide your Personal Data to us (however, please note that there is a possibility that ACLED will be unable to provide you with the full benefit of our Access Portal, or services, if you do not provide us with your Personal Data – e.g., ACLED might not be able to process your requests without the necessary details);
  • the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
  • the right to request rectification of any inaccuracies in your Relevant Personal Data;
  • the right to request, on legitimate grounds:
    • erasure of your Relevant Personal Data; or
    • restriction of Processing of your Relevant Personal Data;
  • the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
  • the right to be informed about disclosures - we will not share your personal data, including employment references, with third parties without a lawful basis. In all cases, this means we will seek your consent or ensure you are informed before any reference or personal employment information is disclosed to external parties;
  • where ACLED processes your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which ACLED receive Policy of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
  • the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the following additional rights regarding the

  • Processing of your Relevant Personal Data:
  • the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf; and
  • the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section 13 below. Please note that:

  • in some cases it will be necessary to provide evidence of your identity before ACLED can give effect to these rights; and
  • where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) ACLED will investigate your request reasonably promptly, before deciding what action to take.

CONTACT INFORMATION

If you have questions, concerns, or requests about this privacy notice or how your data is handled, please contact: [email protected]