Morgan McKinley Recruitment Data Protection Statement

Morgan McKinley provides recruitment solutions, talent solutions and executive search to meet our clients' needs by connecting specialised talent with leading employers across multiple geographies, industries, and disciplines.

We are a recruitment agency and recruitment business as defined in the applicable employment and industry specific legislation and regulations, including but not limited to, the Employment Agencies and Employment Businesses Regulations 2003.

When you apply for a role with Morgan McKinley, your relationship may be with one, or several, companies in the Group depending on your location and the position you are applying for. Each company is referred to herein as a Group Entity and together they are the Group. Each group entity and their location is specified below.

This Data Protection Statement applies to the following companies in the Group.

Group Entity Name	Company Address	Location
Premier Recruitment International Unlimited Company trading as Morgan McKinley	Penrose Dock 2, Alfred St, Victorian Quarter, Cork, T23 YY09, Ireland	Ireland Applicants
Morgan McKinley Group Limited	15 Fetter Lane, Holborn, London EC4A 1BW	UK Applicants
Morgan McKinley Pte Ltd	One Raffles Place Tower 1, Singapore, 048616	Singapore Applicants
Morgan McKinley Ltd	Suite 3407 Lippo Centre, Tower II, 89 Queensway, Admiralty, Hong Kong	Hong Kong Applicants
Morgan McKinley Job Intermediary (Shanghai) Co. Ltd	Unit 3102 - 3104, Level 31, K. Wah Centre, 1010 Middle Huaihai Road, Xuhui District, Shanghai 200031	China Applicants
Morgan McKinley KK (Japan)	Holland Hills Mori Tower 17F, 5-11-2 Toranomon Minato-ku, Tokyo 105-0001, Japan	Japan Applicants
Morgan McKinley Pty Ltd (Australia)	9/383 Kent St, Sydney NWS 2000, Australia	Australia Applicants
Morgan McKinley Services Pvt Ltd	Building No. IV/905.B, Near Shalimar House, Manjakkal, Mahe, Puducherry, India.	India Applicants
Morgan McKinley Inc. (Canada)	Unit 204, 107 Atlantic Ave, Toronto, Ontario, M6K 1Y2, Canada	Canada Applicants

This Data Protection Statement applies to the Personal Data we process about Applicants applying for positions as employees at our company.

For the purposes of this recruitment Data Protection Statement, an applicant includes:

• an active job seeker, who applies to a role that we have advertised; or
• someone we identify as a potential job seeker;

When we refer to “Personal Data” in this Data Protection Statement we mean any information relating to an identified or identifiable natural person ('Data Subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We receive Personal Data about Applicants from a variety of sources. Usually, an Applicant provides us with certain information directly, for example, when the Applicants sends us their CV, applies directly for a position advertised on the Morgan McKinley website or interacts with our communications (e.g. websites and advertisements).

We may also receive Personal Data about an Applicant when:

• the Applicant applies to a position advertised on a third-party job’s website;
• the Applicant may be sourced from publicly accessible platforms such as LinkedIn;
• the Applicants may be sourced from third party CV providers such as jobs websites that provide CV search facilities and where users have made their CV data available to registered customers of these sites; and
• the Applicant’s nominated referees or other individuals may provide us with Personal Data relating to the Applicants.

This section describes the personal data that we collect about Applicants. We only collect the personal data that we require in order to provide and deliver the services that you expect. We have described here the personal data that we use in order to provide our services.

The table below sets out the general categories of Personal Data that we collect in relation to Applicants.

Personal Data Category	Description
Contact Data	may include a person’s name, email address, phone number, postal address, other communication details including social media links (e.g. LinkedIn)
Identification Data	may include a person’s name, date of birth, driver’s license, national tax identification number and passport information
Professional Data	may include information about previous professional experience such as profession, company, department, employment history, skills/experience, membership of professional bodies
Education Data	may include educational history such as degrees, certificates and diplomas awarded, languages and qualifications
CV Data	may include Contact Data, Identification Data, Professional Data, Education Data and information about achievements and hobbies
Application Data	may include information provided when applying for a role such as, CV Data, Financial Data, Position Data, Media Data, and details of visa or eligibility to work.
Financial Data	may include payment and bank details, tax information, payroll information, professional fee rate expectations, Limited/Umbrella company details
Test Data	may include test answers and results for any job application
Health Data	may include health information including information about any disability or illness.
Media Data	may include photographs provided by Applicants
Legal Data	may include criminal record and credit checks undertaken where required as part of the application process.
Position Data	may include information relevant to a position such as rate of pay, working hours, reporting lines, job description and performance
Emergency Contact Data	may include the name and contact details provided by an Applicants in case of an emergency.
Communications Data	may include Personal Data included in communications with us over email, text, phone or letter.
Marketing Data	may include your Contact Data and any preferences in receiving marketing from us and your communication preferences.
Web Data	may include information provided on any forms on our website and, to the extent that it includes Personal Data, information on the type of device you are using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.

We can only collect your Personal Data if we have a lawful basis for doing so.

We have set out in the table below, the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing.

Purpose/Activity	Type of Personal Data	Lawful basis for processing
Applicants Sourcing
to advertise roles on the Morgan McKinley website to create a record/file for the Applicant on our system and to associate all notes and tracking throughout the interview, and onboarding process to keep up to date information about Applicants in relation to their requirements, in order to assess their suitability for current or future vacancies to maintain our database screening and identification of Applicants for available positions to communicate with Applicants about positions that might be of interest to them to receive and review Applicants applications to understand current and expected salary, notice period and availability.	CV Data Communications Data Marketing Data	Legitimate interest Consent
Job Applications
responding to Applicants queries receiving and reviewing applications received from Applicants directly communications with Applicants re application setting up interviews with the Applicant	CV Data Media Data Communications Data	Consent Legitimate Interest Contract
Job Interview
to arrange and undertake interview recording notes of Interview to communicate with the Applicants following interview	CV Data Communications Data	Consent Legitimate Interest Contract
Applicants Screening (where relevant to the position)
to identify if the Applicant is fit to work to assess the Applicant working capacity	CV Data Health Data Test Data	Consent Contract
Applicants Finance Activities
to endeavour that salary expectations are met to remunerate Applicant for interview / travel expenses	Contact Data Position Data Financial Data	Consent Legitimate Interest Contract
Applicants IT Activities
back-up and storage of Applicant data to make improvements and efficiencies in the recruitment process	Contact Data Identification Data Professional Data Education Data Communications Data Marketing Data	Consent Legitimate Interest
Website Delivery
to respond to web forms completed by applicants; to administer the Website; for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes to ensure the safety and security of our website and our services.	Contact Data Web Data	Consent Legitimate Interest
Marketing activities
to respond to any requests from Applicants to send newsletters and other information that may be of interest to participate in recruitment conferences, seminars, events to personalise marketing information to segment and distribute targeted marketing	Marketing Data Contact Data Web Data	Consent Legitimate Interest

We only keep your Personal Data as long as it is necessary for the purposes of processing it or to comply with legal or regulatory requirements.

Our retention policy is as follows:

Purpose of Processing	Retention Period
Job Applications	Unsuccessful Applicants Duration of campaign +18 months Successful Applications Per Employee Notice
Applicant Interview	Duration of campaign +18 months
Applicant Expense Reimbursement	Duration of campaign +7 years

In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate interests. We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims. We may also delete Personal Data earlier than the specified Retention Period where the Personal Data is no longer required for the purpose.

We may need to share your personal data in order to manage our recruitment activities. We will always ensure that any disclosure of personal data is undertaken in compliance with Data Protection Law and ensure that appropriate technical and organisational measures are undertaken to protect and secure any personal data that is transferred.

Personal Data is shared in certain circumstances as follows:

• to other companies in the Group including the affiliated companies documented in this Data Protection Statement for the purposes of administration, marketing and provision of our services
• to business partners and third-party service providers for the purposes of servicing our company and administration of our business, including email, chat, ticketing, Customer Relationship Management, Applicant Tracking System, payment processors, data aggregators, hosting service providers, external consultants, accountants, auditors, IT consultants and lawyers
• if a company in the group or substantially all of its assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets
• if we are under a duty to disclose or share personal data in order to comply with any legal obligation (including tax, audit or other authorities), or in order to enforce or apply any contracts that we have
• to official authorities to protect our rights, property, or safety, or those of other persons (including you)
• to payment service partners for the processing of payments to and from our business,
• to protect our rights, property, or safety, or that of our customers or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection
• for the purposes of third-party screening and verification, including doctors or testing companies (for example, criminal record checks / pre-employment screening services and assessments)
• to analytics and search engine providers that assist us in the improvement and optimisation of our Website. This consists of information relating to the web pages visited on the Website and tracking codes from service providers like LinkedIn and Google
• to insurance brokers and providers where required for administering claims
• to our email distribution partner and service providers in the case of marketing and newsletter

We monitor for and do everything that we can to protect personal data and prevent security breaches.

We will take all steps reasonably necessary to ensure that all personal data is treated securely in accordance with this Data Protection Statement and the Data Protection Laws. In particular, we employ appropriate technical and organisational procedures to safeguard and secure the personal data we process to prevent unauthorised access.

We monitor for and do everything we can to prevent security breaches of the personal data that we process. Once we have received your personal data, we will use strict procedures and security features for the purpose of preventing unauthorised access and ensuring that only those who need to have access to your personal data can access it.

We also use secure connections to protect personal data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential. Please do not share your password with anyone.

If you think that there has been any loss or unauthorised access to personal data of any individual, please let us know immediately.

In some circumstances we may need to transfer personal data outside of the country where it was originally collected. We will always undertake such transfers in accordance with data protection laws.

We may transfer Personal Data outside of your home country; however, we will always ensure that this is done in compliance with the relevant laws of your country.

We will normally use and share personal data outside of your country for the following reasons:

• to carry out corporate oversight of our global business organisation
• to provide shared services in certain functions such as HR, Talent Acquisition, Finance, Marketing, Legal, Privacy and IT
• to deploy certain tools and resources across the global organisation
• to facilitate interactions between our employees across our global locations
• to work with our group companies

It is important to be careful when visiting third party websites and when providing personal data to third parties. We have no control over third party websites that you may access.

Websites that you access via a link on the Morgan McKinley website are outside our control and are not covered by this Data Protection Statement. If you access other websites using the links provided, the operators of these websites may collect Personal Data from you, which will be used by them in accordance with their own Data Protection Statements, which may differ from ours. Please check the Data Protection Statements on those websites before you submit any Personal Data to them.

Please see our separate Cookie Notice available at

https://www.morganmckinley.com/ca/cookies-policy for further information.

We will update the date on this Data Protection Statement when we make changes to it.

We will post any changes to this Data Protection Statement on the Website and when doing so will change the effective date at the top of this Data Protection Statement.

In some cases, we may provide you with additional notice of changes to this Data Protection Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.

Please contact us if you have any questions or concerns about how your personal data is being used by us.

You have various rights relating to how your Personal Data is used.

Right of access to Personal Data

You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to everything we have recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.

We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.

We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others.

Right of rectification of Personal Data

You should let us know if there is something inaccurate in your Personal Data.

We may not always be able to change or remove that Personal Data, but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

Right of erasure of Personal Data (right to be forgotten)

In some circumstances you can ask for your Personal Data to be deleted, for example, where:

• your Personal Data is no longer needed for the reason that it was collected in the first place
• you have removed your consent for us to use your Personal Data (where there is no other lawful basis for us to use it)
• there is no lawful basis for the use of your Personal Data
• deleting the Personal Data is a legal requirement

Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.

Please note that we cannot delete your Personal Data where:

• we are required to have it by law
• it is used for freedom of expression
• it is used for public health purposes
• it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing
• it is necessary for legal claims.

Right to restrict what we use your Personal Data for

You have the right to ask us to restrict what we use your Personal Data for where:

• you have identified inaccurate Personal Data, and have told us of it
• where we have no legal reason to use the Personal Data, but you want us to restrict what we use it for rather than erase the Personal Data altogether

When Personal Data is restricted it cannot be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it's for important public interests.

Right to have your Personal Data moved to another provider (data portability)

You have the right to ask for your Personal Data to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.

This right only applies if we are using your Personal Data with consent and if decisions were made by a computer and not a human being. It does not apply where it would adversely affect the rights and freedoms of others.

Right to object

You have the right to object to processing of your Personal Data which is based on public interest or legitimate interest processing. We will no longer process the Personal Data unless we can demonstrate a compelling ground for the processing.

Right not to be subject to automated decision-making

You have the right not to be subject to a decision based solely on automated processing. This right shall not apply where the processing is necessary for a contract with you, or the processing is undertaken with your explicit consent or the processing is authorised by law.

You can make a complaint

You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.

Please contact us using the following details if you have any questions or concerns:

If You consider that the processing of personal data infringes the GDPR or local Data Protection and Privacy Laws, you have the right to lodge a complaint with or consult with your local Data Protection Authority.

We have provided contact details for the relevant Data Protection authorities below, where possible:

• In the UK, the Information Commissioner's Office (ICO);
• In Ireland, the Data Protection Commissioners office (DPC);
• In Japan, the Personal Information Protection Commission;
• In Hong Kong, the Office of the Privacy Commissioner for Personal Data (PCPD);
• In Australia, the Office of the Australian Information Commissioner (OAIC);
• In Canada, the Office of the Privacy Commissioner of Canada(PIPEDA);
• In Singapore, the Personal Data Protection Commission (PDPC);
• In China, the Cyberspace Administration of China (CAC) (国家互联网信息办公室).
• In India, please note, currently no authority exists.

You also have the right to lodge a complaint with the Data Protection Commission (DPC) in Ireland
The contact details for the DPC in Ireland are:

Webform: https://forms.dataprotection.ie/contact

Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Address: +353 578 684 800

Address: +353 761 104 800