Recruitment Privacy Notice

i) Introduction

This Notice explains how Hamilton Safe handles Personal Data about our job applicants and the rights applicants have under data protection law. We refer to this type of information as "Application Data."

This Notice applies to applications submitted via job pages, LinkedIn, Indeed, Hamilton Safe's website or intranet, and third parties, such as recruitment agencies and job boards. It also applies to applications submitted via other means, such as post and email.

Please refer to the Glossary below for an explanation of the defined terms in this Policy.

ii) Overview: the Hamilton Safe 10 Data Protection Principles

Hamilton Safe observes the Hamilton Safe 10 Data Protection Principles about Application Data:

Fairness and Transparency: Give people information about how Hamilton Safe processes their Application Data.

Lawful Processing: Make sure we always have a good, lawful reason to process Application Data.

Purpose Limitation: Only collect Application Data for a specific business need of Hamilton Safe. If we want to reuse the Application Data for a new purpose, we must make sure the two are compatible.

Data Minimization: Only process as much Application Data as we need, and no more.

Accuracy: Keep Application Data accurate, complete, and up-to-date.

Retention: We should only keep Application Data for as long as necessary. If we no longer need it, we must delete it or anonymize it.

Security: Protect Hamilton Safe's Application Data from getting lost or stolen. Make sure our service providers protect our Application Data as well.

Individual Rights: Individuals should be able to access, correct, or erase their Application Data or object to its use for certain purposes.

Application Data Transfers: Put safeguards in place before sending application data outside of the US.

Accountability: Hamilton Safe will take steps to make sure our processing of Application Data complies with these 10 Data Protection Principles.

iii) What Application Data does Hamilton Safe collect?

Hamilton Safe will generally only collect Application Data in the recruitment process necessary to assess you for the post you applied for. This may include the following categories:

• Information you provide to set up an account ("Profile") on job pages, such as your email address;
• Information you provide to apply for a job vacancy with Hamilton Safe to tell us who you are and to build a picture of your capabilities and suitability for certain positions, such as your name, contact information, nationality, professional qualifications, previous employment history, personal interests, experiences and a copy of your résumé;
• Information collected by Hamilton Safe as a result of the recruitment process, such as your performance at assessment centers, interviews, or in other assessments and information provided by your referees; and
• Information related to your use of our website, such as your IP address, may be collected using cookie technology. For more information about how Hamilton Safe uses cookies, please see our Privacy Policy.

Personal Data about criminal convictions or medical information will only be sought where local law permits.

We will indicate whether the information we have requested is mandatory or optional.

iv) What will Hamilton Safe do with your Application Data?

The main purposes for which we use Application Data include:

Supporting and processing your job application, for example, so we can assess your ability to meet the job specification, in order to shortlist applicants and verify references and professional qualifications provided by those applicants;

Improving our application process, for example, to ensure that our website, intranet, and job-page portal are user-friendly and contain appropriate and helpful information; and

[Ensuring compliance with our Code of Conduct, for example, to ensure that we are living up to our values and, in particular, for equal opportunities monitoring purposes.]

We may verify the Application Data you provide during the recruitment process and/or collect Personal Data about you from sources other than you to assist with our 'Pre-Employment Checks'. This may include checking your qualifications, directorships, financial history (e.g., bankruptcy), and if you have a criminal record. If this occurs:

You will be told in advance which aspects of your Application Data will be verified including an explanation of how the Pre-Employment Checks will be carried out; and

Information about criminal convictions (if collected) or medical information will only be collected through official authorized sources and in accordance with applicable law.

Where it is necessary and appropriate to you're the role you have applied for, we may also require you to undertake drug and alcohol testing prior to commencing your employment with us.

IMPORTANT: If you indicate that you do not have the right to work in the country in which you are applying for a position, the system will automatically drop your application and it will not be reviewed by Hamilton Safe. However, if you would like to explain your circumstances to us, please contact us using the contact information set out in paragraph 9 below.

Hamilton Safe will only process your Application Data where we have a legal basis for doing so. Hamilton Safe's processing of Application Data is generally because it is necessary for us to decide whether to enter into a contract of employment with you. In addition, certain data processing may be based on your consent (which you have the right to withdraw) or because it is necessary to comply with a legal obligation or to enable us to pursue our legitimate business interests (for example where it is necessary to understand our applicants in sufficient detail so we can deliver an effective recruitment service).

v) Who is your Application Data disclosed to?

a. Within Hamilton Safe

Hamilton Safe restricts access to Application Data to people within Hamilton Safe who have a "need to know" that information. For example, certain individuals throughout Hamilton Safe will have access to your Application Data in order to process your job application and manage the recruitment cycle.

b. Outside Hamilton Safe

Hamilton Safe shares Application Data with authorized third-party service providers to conduct and manage recruitment. For example, we may share your personal information with these service providers to screen and verify your application and the information you have provided to Hamilton Safe. This includes verifying academic and professional qualifications.

Generally, Hamilton Safe will only disclose your Application Data to third parties outside Hamilton Safe and its suppliers:

when required to do so by law;

in response to a legitimate request for assistance by the police or other law enforcement agency; and

to seek legal advice from Hamilton Safe's external lawyers or in connection with litigation with a third party.

vi) How long will Hamilton Safe retain your Application data?

We keep your application data according to our internal retention policies and procedures. Typically, if you are unsuccessful in your job application with us (or if you reject the position), your Application Data will be destroyed usually within [6-18 months] (depending on the jurisdiction) to comply with our legal obligations and so that we may contact you again if another suitable position arises. Please contact us if you would like more information on how we retain your application data.

If you successfully apply and join Hamilton Safe, we will retain your Personal Data under our internal data retention guidelines and procedures. More information will be provided when you start.

vii) Where does Hamilton Safe store your Application data?

Applicants should be aware that their Application Data may be transferred to and stored at a destination outside their country of residence, which may have less strict or no data protection laws than those of their country of residence. It may also be processed by staff operating outside of their country of residence who work for us or for one of our suppliers, for example, in the provision of support services.

Whenever we transfer your Application Data outside of your country of residence, we will take legally required steps to ensure that adequate safeguards are in place to protect your Application Data and to make sure it is treated securely and in accordance with this Notice. If you are located in the EEA or the UK, you may contact us for a copy of the safeguards that we have put in place to protect your Application Data and privacy rights in these circumstances.

viii) Exercising your rights

You may have the right to request access to, rectification, or erasure of the Application Data Hamilton Safe holds about you. You may also have the right to object to or restrict certain types of processing of your Application Data and request to receive a machine-readable copy of the Application Data you have provided to Hamilton Safe. Remember that you can update your contact information in your online account Profile.

Any request to exercise one of these rights will be assessed by Hamilton Safe on a case-by-case basis. There may be circumstances in which we are not legally required to comply with your request because of the laws in your jurisdiction or because of relevant legal exemptions provided for in data protection legislation.

ix) Contact us

Please contact Hamilton via our website if you would like to find out more about any matters relating to this Notice or to exercise your rights as outlined in paragraph 8 above.

If you have concerns about how Hamilton Safe has handled your Application Data, you can complain to your Data Protection Authority. However, we encourage you to raise these concerns with Hamilton Safe in the first instance.

Glossary

Application Data: Personal Data relating to job applicants.

Data Protection Authority: The relevant supervisory authority responsible for privacy or data protection matters in the jurisdiction of Hamilton Safe and/or a Hamilton Safe, LLC.

Personal Data: Information that relates to an identified or identifiable individual (i.e., data about Hamilton Safe employees, contractors, applicants, employees of vendors and suppliers, contractors, customers, patients using our products, and individuals who use our website or service centers). It includes names, email addresses, job applications, user account information, and correspondence. Personal Data can also include web browsing information (e.g. data associated with a particular cookie) and IP addresses, when such information can be linked to an individual.

Pre-Employment Checks: Personal Data relating to a potential Hamilton Safe employee collected from sources other than the candidate, such as directorships, financial history, qualifications, and criminal record.

Processing: Doing anything with Personal Data includes collecting it, storing it, accessing it, combining it with other data, sharing it with a third party, or even deleting it.