DATA PROTECTION PRIVACY NOTICE FOR RECRUITMENT
This notice explains what personal data (information) we will hold about you from which you can be identified, how we collect it, and how we will use and may share information about you during the application process. This does not include data where your identity has been removed (anonymous data) but may include “special categories” of more sensitive personal data which require a higher level of protection. For handling recruitments and for simplifying the hiring process we use Teamtailor’s services (‘Services’). We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
WHO COLLECTS THE INFORMATION
Vaimo is a group of companies listed here under “Vaimo affiliated companies” singularly or together referred to as ‘Vaimo’ and, in this notice, references to ‘we’ or ‘us’ meaning Vaimo. Vaimo is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies.
ABOUT THE INFORMATION WE COLLECT, HOLD AND LEGAL BASIS
We collect and process personal data at different stages of the recruitment process to evaluate your suitability for employment at Vaimo.
Up to and including the shortlisting stage
Through your application and our recruitment platform (the "Service"), we may collect:
Contact Information: Your full name, home address, email address, and phone numbers;
Application Documents: Your CV, cover letter, and any other documentation provided, including details of your qualifications, employment history, job titles, working hours, and professional interests or other documentation provided during the recruitment process;
Service & Social Data: Emails, pictures, videos, titles, education history, and information imported from your Facebook or LinkedIn accounts if you choose to connect them;
Assessments & Videos: Results of any test completed during the application, including automated video interviews where you answer pre-recorded questions;
References: Names and contact details of your chosen referees.
After the shortlisting stage (before a final hiring decision)
To verify your background and fulfill legal requirements, we may collect:
Employment & Academic Verification: Information regarding your academic and professional qualifications, as well as references from previous employers or education providers (including details on performance, attendance, conduct, or grievances);
Right to Work Documentation: Your nationality, immigration status, and copies of related documents (e.g., passport, visa, or identity card).
Sensitive and Criminal Record Data
Criminal Convictions: Where legally permissible and strictly necessary for the role, we may collect information regarding your criminal record. You will always be notified in advance before we conduct such checks and where necessary, we will ask your consent.
Other Sensitive Data: In limited circumstances, if the need arises to process "special category" data (e.g., health or diversity data), we will approach you for your explicit written consent. We will provide full details on why it is needed so you can carefully consider your choice. You are under no obligation to provide this consent.
Use of Artificial Intelligence (AI) and Automated Tools
We may use artificial intelligence, machine learning, or automated software tools during our recruitment process to help manage applications, analyze resume data, or process pre-recorded video interviews (the "Service"). These tools help us streamline the administrative phases of recruitment. Specifically, the automated tools analyze your application (such as your CV, cover letter, and assessment responses) by identifying and highlighting keywords, qualifications, and experience that align with the requirements of the specific role for which you have applied. This process assists our talent acquisition team in organizing applications and identifying potential matches for further manual consideration.
We do not use any tools to make solely automated decisions or candidate profiling that would result in the automatic rejection or selection of an applicant without human intervention. Every decision to shortlist, advance, or reject an application is actively reviewed and made by a member of our talent acquisition team.
Purposes and Legal Basis for Processing
The primary purpose of collecting and processing your personal data is to effectively manage our recruitment workflows, evaluate your application, and fulfill our duties as a potential employer.
We rely on the following legal grounds to process your personal data during the recruitment process:
Pre-Contractual Steps: Processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into an employment contract. This includes processing your application to determine whether we can offer you an employment agreement.
Legitimate Interests: Processing is necessary for our legitimate interests to simplify, streamline, and facilitate our recruitment process. Specifically, this includes processing your credentials, application documents, and interview data to evaluate whether you are a suitable candidate for the relevant role.
Legal Obligations: Processing is necessary to meet our statutory and legal obligations as an employer, such as verifying your legal right to work, nationality, and immigration status prior to hiring.
Consent: Where you have explicitly granted permission for a specific, separate purpose—such as retaining your profile to inform you of future vacancies. You are under no obligation to provide consent, and you may withdraw it at any time.
You have the right to withdraw your consent at any time, by contacting us at GDPR@vaimo.com. Using this right may however, mean that you can not apply for a specific job or otherwise use the Service.
In limited circumstances, if the need arises, we will approach you for your written consent to allow us to process certain information. If we do so, we will provide you with full details of the information that we would like to process and the reason why, so that you can carefully consider whether you wish to consent. You should be aware that you are not obliged to agree to any request for consent from us.
HOW WE COLLECT THE INFORMATION
We collect personal data about you through various channels during the recruitment lifecycle, categorized as follows:
Information Provided Directly By You
We collect data directly from you when you interact with our recruitment processes, including when you:
Submit an application, CV, cover letter, or digital forms through our recruitment platform (the "Service") or via email;
Complete assessments, skills tasks, or tests as part of our evaluation and selection process;
Use the Service to connect or communicate with our Talent Acquisition team or Vaimo staff;
Provide personal data within the interactive chat functionalities provided on our career sites, where that data is relevant to your application procedure.
Information Collected via Third-Party Sources and "Sourcing"
We may collect information about you from public platforms, professional networks, or external individuals. This processing is based on our legitimate interest to identify and evaluate suitable candidates:
Professional & Social Networks: When you apply or connect with us using a third-party account (such as LinkedIn or Facebook), or when our team manually or automatically reviews public profiles on these platforms to identify potential talent (referred to as "Sourcing").
Employee Referrals: When an existing Vaimo employee recommends you for a vacant position and provides us with your professional contact details and background.
Information Collected from External Verification Bodies
Consistent with taking pre-contractual steps and fulfilling our legal obligations, we may collect data from external parties, typically after the shortlisting stage:
Referees whose details you have provided to us;
Your previous employers or education providers to verify your academic and employment history;
Relevant professional certification bodies or government authorities (such as immigration services to verify your right to work).
HOW WE USE YOUR PERSONAL DATA
We use the personal data we collect throughout the recruitment cycle for specific operational purposes necessary to run our talent acquisition process.
Core Recruitment Operations
We process your data to execute standard hiring activities, which align with taking pre-contractual steps and fulfilling our legitimate interest to evaluate candidate suitability:
Application Evaluation: To assess your skills, qualifications, work history, and overall suitability for the specific position you applied for;
Communication: To contact you regarding your application, schedule interviews, administer recruitment tests, or send automated video interview requests;
Background & Reference Checks: To contact your designated referees and verify your past professional and academic history (typically conducted only after an initial offer or shortlisting stage);
Onboarding Preparation: If your application is successful, to generate your employment offer and establish your initial internal personnel record. (Subsequent employment processing is governed by our separate Employee Data Protection Privacy Notice).
Legal Compliance & Rights Verification
Eligibility Checks: To fulfill our statutory duties as a prospective employer by verifying your nationality, immigration status, and legal right to work in the country where the respective Vaimo group company is incorporated.
Talent Pool Talent Sourcing (Subject to Consent)
Analytics, Quality Assurance, and Anonymization
Process Optimization: To perform internal statistical analysis and analytics regarding our applicant demographics, evaluate the efficacy of our recruitment channels, and validate the fairness and objectivity of our testing methodologies;
Data Anonymization: Personal data used for aggregated statistical analysis, reporting, or market research is permanently and irreversibly anonymized. Because this data can no longer be used to identify a specific individual, it ceases to be personal data under applicable data protection laws.
HOW WE MAY SHARE THE INFORMATION
We may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations and are required to take appropriate security measures to protect your information in line with our policies. We do not allow our third-party service providers to use your information for their own purposes and only permit them to process your information for specified purposes and in accordance with our instructions. We may also be required to share some personal information with our regulators or as required to comply with the law.
TRANSFERRING INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
If we need to transfer your information we collect about you outside the EEA, to ensure that your information receives an adequate level of protection, we will only make transfers: (i) to a country which the European Commission has made a positive finding of adequacy for, or (ii) under the standard clauses approved by the European Commission to ensure that adequate safeguards are in place to protect your rights as a data subject.
FAILURE TO PROVIDE INFORMATION
If you fail to provide certain information when requested, we may not be able to consider application further or continue with the recruitment process, or we may be prevented from complying with our legal obligations.
WHERE INFORMATION MAY BE HELD
Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents, including Teamtailor in respect of information submitted or processed through the Service..
HOW LONG WE KEEP YOUR INFORMATION
We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.
We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If you have given us consent to process your information to inform you about future vacancies, your information will be stored as long as we have your consent for such processing, we will only keep it for a maximum of 2 years from the day you gave us that consent. Once those 2 years are up, we will safely delete your information or completely anonymize it so you can no longer be identified. If we still need to use it to serve you, we will ask you to renew your consent before the time runs out.. If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see Employee data protection privacy notice.
YOUR RIGHTS
Under certain circumstances, you have the right to:
Request access to your information. This enables you to receive a copy of the information we hold about you and to check that we are collecting and using it lawfully.
Request correction of the information 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 request the deletion or removal of your personal data where there is no overriding legal ground for us to continue processing 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. However, this right is not absolute; we may be legally obligated to retain certain aspects of your data to comply with applicable statutory retention periods (such as the Equal Treatment Act, or corporate laws).
Object to processing of your information. This applies 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.
Request the restriction of collecting and using your information. This enables you to ask us to suspend the usage of information about you, e.g. if you want us to establish its accuracy or the reason for processing it.
Request the data portability of your information to another party.
Lodge a complaint to supervisory authority.
Withdraw consent. In circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to.
Please contact our legal department, via email GDPR@vaimo.com if (in accordance with applicable law) you would like to access, review, verify, correct or request erasure of your information, object to the processing of your information, request that we transfer your information to another party or withdraw the consent or if you have any questions about this notice.
In order to meet your request we may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
Exercising your rights is free from charges. However, we have right at our sole discretion to refuse to fulfil or charge a reasonable fee for fulfilling of several similar consecutive requests or requests that are manifestly unfounded or excessive. We are also entitled to decline requests on statutory grounds in which cases we will inform you of the reasons for this.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
INFORMING US OF CHANGES TO YOUR INFORMATION
It is important that the information we hold about you is accurate and up to date. Please keep us informed if your personal information changes.
COOKIES
When using the Teamtailor website, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on your device, such as computer, mobile phone or tablet. Cookies are used to improve your usage and to gather information about, for example, statistics about the website usage. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by Cookie Policy.
You can at any time disable the use of cookies by changing the local settings in your devices. Disabling of cookies can affect the experience of the Service, for example disabling some functions in the Service.
HOW TO COMPLAIN
If you have any concerns about how we handle your personal data during the recruitment process, we encourage you to contact us directly so we can resolve the matter. However, you also have the right to lodge a complaint at any time with the relevant data protection supervisory authority in your country of residence, place of work, or the place where the alleged infringement occurred. Additionally, if your concern relates to your rights as a candidate, you may turn to the supervisory authority responsible for employment and labor-related matters in your jurisdiction.
