Legal Information
Candidate Privacy Notice
Table of contents:
- Who are we and what is the purpose of this notice?
- Definitions
- Personal Information we collect and how we use it
- International data transfers
- Data Retention
- Children’s policy
- Your rights
- Governing Law
- Changes to this Notice
- Contact us
- Notice for Individuals in the UK and EEA
- Notice for individuals in California
- Acknowledgement
1 Who are we and what is the purpose of this Notice?
Zafin and its group of companies (“Zafin”, “we”, “us” or “our”) are committed to protecting the privacy and security of Personal Information and handling it in accordance with data protection and privacy laws.
This privacy notice (“Notice”) is part of the Zafin privacy program. It describes how we collect, use, and disclose your Personal Information and how your Personal Information can be reviewed and corrected when necessary. We have published this Notice to ensure that you are fully aware of what Personal Information we collect from you, how we Use it, who we share it with, and what your rights are. This Notice applies to employment, internship, and scholarship applicants.
2 Definitions
We have included the following definitions to help you understand the contents of this Notice:
“Collection” occurs when Zafin finds itself in custody or control of personal information. Note that this includes information that Zafin receives even when the data was not requested.
“Consent” is an individual’s freely given, specific and informed agreement to the processing of their personal information.
“GDPR” means the General Data Protection Regulation (EU) 2016/679.
“Personal Information” means information about an identifiable individual and includes the term “Personal Data” under the GDPR and UK GDPR.
“PIPEDA” means Canada’s federal Personal Information Protection and Electronic Documents Act S.C. 2000, c. 5.
“Process” is an operation or set of operations performed upon personal information.
“UK GDPR” means the General Data Protection Regulation, Regulation (EU) 2016/679 as it forms part of domestic law in the United Kingdom by virtue of section 3 of the EU (Withdrawal) Act 2018 (including as further amended or modified by the laws of the United Kingdom or a part of the United Kingdom from time to time).
“Use” means the process of collecting, accessing, storing, reading, modifying, analyzing, or changing Personal Information. This includes when Zafin uses a service provider or vendor to carry out these tasks on its behalf.
3 Personal Information we collect and how we Use it
Personal Information means information about an identifiable individual. In other words, Personal Information is data about you that a person may use to identify you. We take steps designed to ensure that only those who need access to your Personal Information to fulfill their duties can access it. We have set out below where we collect your Personal Information, what we collect, and how we Use it.
3.1 How we collect Personal Information and what we collect when you apply for an internship or employment:
In connection with your application for employment or internship opportunity, Zafin will collect and create personal information about you during the course of your application with Zafin.. This includes:
- Contact Information: Full name, email address, phone number, and home address.
- Evidence of how you meet the requirements of the opportunity such as a resume/CV or cover letter, employment and/or educational history, right to work documentation, professional qualifications, interview notes, correspondence with Zafin or its recruiters with regard to applications (including references) and any other information you provide as part of the application process.
- Identification information such as a copy of a passport or work permit.
- Educational Background: School or institution name, academic records, and major/course of study.
- Work experience: Previous employers, roles held
- Background check reports
- References: Including letters of recommendation
- Demographic Information: Date of birth, gender, nationality, and other relevant demographic data.
3.2 How we collect Personal Information and what we collect when you apply for a scholarship:
In connection with your application for a scholarship opportunity, Zafin will collect and create personal information about you during the course of your application with Zafin.. This includes:
- Contact Information: Full name, email address, phone number, and home address.
- Educational Background: School or institution name, academic records, and major/course of study.
- Scholarship Application Details: Information provided in the scholarship application form, including essay responses, letters of recommendation, and other submitted materials.
- Demographic Information: Date of birth, gender, nationality, and other relevant demographic data.
3.3 How We Use Your Information
We use the collected Personal Information for the following purposes:
- Employment or Internship Application: To assess your suitability for employment and qualifications for the opportunity.
- Scholarship Application Evaluation: To assess your eligibility and qualifications for our scholarship program.
- Identification & Verification: To conduct background checks and verify the information provided.
- Communication: To contact you regarding your application status, additional information requests, and employment, internship, or scholarship-related updates.
- Compliance with Legal Obligations: To comply with applicable laws, regulations, and reporting requirements.
- Aggregated Data Analysis: To analyze and improve our recruitment and scholarship program and related initiatives, while ensuring individual data remains anonymized.
3.4 Sensitive Information
We do not collect sensitive information, such as race, ethnicity, religious beliefs, health information, or criminal records, unless required by law or with your explicit consent.
3.5 Legal Basis for Processing Personal Information
Under data protection law we must have a legal basis to Use your Personal Information. We will only Use the Personal Information we receive from you to process your scholarship application and it is in your reasonable expectations that we would need to Use your Personal Information to be able to evaluate your application.
Our processing of your Personal Information is based on the following legal grounds:
- Consent: Where we Use your Personal Information for processing your candidacy request, we do this on the basis that you have consented to Zafin accessing your Personal Information to evaluate your application. You have the right to change your mind about this at any time. Please note that withdrawing consent will result in termination of your application. To withdraw your consent, follow these steps, as applicable:
- For employment applications, please contact us via our website or email the recruitment contact and copy [email protected].
- For internship applications, please contact us via our website or email us at [email protected].
- For scholarship applications,
- Contractual Necessity: Processing is necessary for the management of the agreement between you and Zafin.
- Legitimate Interests: We have a legitimate interest in improving our recruitment & selection programs.
- Legal basis: Necessary for taking steps prior to entering into a contract and for compliance with legal obligations to which we are subject.
3.6 Data Sharing and Disclosure
We may share Personal Information with trusted service providers for processing and to help us provide, maintain, and improve our recruitment processes and scholarship program. We remain accountable for that Personal Information’s privacy and security and use contractual or other means to ensure that service providers meet our privacy and security requirements.
We may share your personal information with the following parties:
- Zafin Representatives: Our employees and authorized representatives involved in the application management, evaluation, and selection process.
- Third-Party Service Providers: Trusted third-party service providers, such as application tracking systems, interviewers / evaluators, and background verification services, to assist us in managing and assessing applications.
- Entities, organizations or individuals for legal reasons: We will share your Personal Information with entities, companies or individuals where this is strictly necessary to comply with any law, rule, regulation, governmental request or legal procedure that is applicable to us.
- Entities, companies or individuals to obtain advice: We will share your Personal Information with external professional advisors such as lawyers or accountants in order to take advice and for the purposes of legal and tribunal proceedings or enforce the terms of our agreements.
We will only disclose such Personal Information to any third party as is necessary to enable them to carry out the function or purpose for which it is disclosed. If you would like further information on the third parties we may share your Personal Information with and our legal basis for sharing your Personal Information with third parties, please contact the Privacy Office (see How to Contact Us).
4 International Data Transfers
In some cases, your personal information may be transferred to and processed in countries outside of your own. We will ensure that adequate safeguards are in place to protect your data during such transfers, in compliance with applicable laws.
5 Data Retention
We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Once no longer needed, we will securely delete or anonymize your data.
6 Children’s Policy
The application is not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, please do not engage in the application process at any time or in any manner. If we learn that Personal Information has been collected from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided Personal Information, then you may alert us as set forth in the “How to Contact Us” section and request that we delete that child’s Personal Information from our systems.
7 Your Rights
On written request and subject to proof of identity, you may:
- Access copies of the Personal Information we hold about you;
- Request that any necessary corrections be made, where applicable, as authorized or required by law; and
- Request deletion of your Personal Information, where applicable, as authorized or required by law.
To ensure that the Personal Information we maintain about you is accurate and up to date, please inform us immediately of any change to your Personal Information by logging into the application portal, as applicable, and editing your profile.
8 Governing Law
Zafin is based in Canada and is governed by the applicable privacy and data protection laws in Canada. Your Personal Information may be stored or processed in any country in which Zafin or its service providers have facilities, and by completing and submitting this application you agree to the transfer of your information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held. It may be subject to disclosure to the governments, courts, law enforcement, or regulatory agencies of such another country, pursuant to such a country’s laws.
9 Changes to this Notice
We may change this Candidate Privacy Notice. Changes to this Notice become effective when posted on our website, please note the “Last Updated” date. Your continued use of the website after the revised Notice has become effective indicates that you have read, understood, and agreed to the current version of the Notice.
10 Contact Us
If you have any questions or comments about this Notice or your Personal Information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices, our Privacy Office can be reached using the following information:
| 401 W. Georgia St., Suite 1701 Vancouver, British Columbia V6B 5A1 Attention: Privacy Office | |
| [email protected] |
11 Notice for individuals in the UK and EEA
If you are based in the UK or EEA, please note that the term Personal Information used in this Notice is equivalent to the term “personal data” under the GDPR and other applicable European data protection laws. Canada’s laws have been determined to be ‘adequate’ by the Commission of the European Union, which means that we are providing equivalent protection to you by complying with Canadian law. For additional information, refer to Zafin’s Privacy Notice.
We will Use your Personal Information to administer our application process including carrying out right to work and other mandatory legal checks. This Use is on the legal basis that it is necessary for taking steps prior to entering into a contract and for compliance with legal obligations to which we are subject.
12 Notice for individuals in California
We only collect personal information about you that will allow us to make a decision about whether to extend an offer of employment to you or that we are required to obtain by law. You have the choice to provide us with the requested information. If you do not provide us with the information and we cannot determine your eligibility for the employment position, it could result in us deciding not to pursue your recruitment.
Zafin obtains the categories of personal information listed in section 5 above.
As defined in the CCPA, personal information does not include:
- Publicly available information from government records; or
- De-identified or aggregated consumer information.
13 Acknowledgement
By submitting your application, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal information as described herein.
