Privacy notice for candidates
Threefold Digital Limited (“Threefold Systems”) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you as part of the recruitment process.
It is important that you read this notice so that you are aware of how and why we are using your data.
Data Protection Principles
We comply with all relevant data protection principles, and this means the personal data we hold about you is:
- 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;
- 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 information we hold about you, and why
Threefold Digital Limited (“Threefold Systems”) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
We collect personal data about candidates through the recruitment process, either directly from them or through recruitment agencies. We may sometimes collect additional information from third parties including former employers or other background check agencies where required.
In order to assess your application and communicate with you about the recruitment process, we may collect and hold about you the following categories of personal data:
- Contact details such as name, title, address, telephone number and email address;
- CV or cover letters or any other supplementary document provided during the application process;
- Information about your right to work in the country;
- Information regarding your work experience, qualifications and education, or employment references;
- The results of any personality profiling assessment that we may carry out as part of the recruitment process; and
- Criminal convictions and offences (where the nature of the role requires this).
We only use your personal data if the law allows us to, and most commonly, for the following purposes:
- In order to take steps to enter into a contract with you – if your application is successful, we will retain that personal data in order to perform that contract;
- Where we need to comply with a legal obligation (for example, we are required to check a successful candidate’s eligibility to work in the country before employment starts);
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Processing candidates’ data allows us to manage the recruitment process, assess a candidate’s suitability for employment and make the appropriate recruitment decision; and
- To respond to and defend against legal claims
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide information which is necessary for us to consider your application (such as evidence of qualifications or work history) when requested, we may not be able to process your application properly or at all. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the country and satisfactory references.
We will only use your personal data for the purposes for which we collected it unless we reasonably believe we need to use it for another reason and that reason is compatible with the original purpose. We will notify you if that is the case and explain the legal basis which allows us to use the data.
Please note we may process personal data without your knowledge or consent where this is required by law or other regulations.
Your application will be assessed by members of the People Team, relevant hiring managers and interviewers involved in the recruitment process. We may also have to share your data with third parties, including third-party service providers (e.g. work agencies) and other entities in the Agora Group.
1. Third parties
We may share your information with third party service providers (such as recruitment agencies or applicant tracking software providers) which provide technical and support services in relation to the recruitment process.
We require third parties to respect the security of your data and to treat it in accordance with the law. They will not share your personal information with any organisation apart from us and they will hold it securely and retain it for the period we instruct them to.
We may also share your personal information with a regulator or otherwise to comply with the law.
2. Other Agora Companies
We may share personal data with other Agora entities as part of recruitment support, regular reporting, reorganisations and for system maintenance, support, and hosting of data. In certain circumstances and when there is a genuine business purpose, this may include members of People Teams in other Agora entities assisting with the application process.
To ensure personal data is adequately protected, data transfer agreements are in place with the US Agora entities.
Your personal data during the recruitment process
Please keep us informed of changes to your personal data so we can ensure it is current and accurate.
You can request access to your personal data, that it be corrected (if it is incomplete or inaccurate), ask us to delete it (where there is no good reason for us continuing to have it), object to its processing where we are relying on a legitimate interest (and your legitimate interest overrides ours), request restrictions on the processing or that it be transferred to another party.
If you are asked to provide your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent at any time by writing to a member of the People Team. Once we are aware you have withdrawn consent, we will no longer process your data for those purposes unless we have another legitimate basis for doing so.
If your application is unsuccessful, we will retain your personal information for  months after we have communicated our decision to you. We retain your personal information 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 information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
If your application is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment.
Automated Decision Making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. Should we ever use automated decision-making that will have a significant impact on you, we will let you know in advance and give you an opportunity to object.
If you would like to exercise any of your rights or if you have any questions about this notice or our processing of your data more generally, please contact a member of the People Team. If you believe we have not complied with our data protection obligations, you can also lodge a complaint with the local data protection supervisory authority.
Last updated 1 October 2019